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HomeMy WebLinkAbout20150225IPC to Staff 1-33.pdfS!ffi*. An IDACORP Company JULIA A. HILTON Gorporate Gounsel ihi lton@idahooower.com February 25,2015 ?frti rill 25 Pl'l h: 28 lil,';'-.'; r: tt'tiii': -:"'',,.'l-, r;.i]t'...'l it-l I VIA HAND DELIVERY Jean D. Jewel!, Secretary ldaho Public Utilities Commission 472 West Washington Street Boise, ldaho 83702 Re: Case Nos. IPC-E-14-41and PAC-E-14-11 Exchange of Certain Transmission Assets - ldaho Power Company's Response to the First Production Request of the Commission Staff to ldaho Power Company Dear Ms. Jewell: Enclosed for filing in the above matters please find an original and three (3) copies of ldaho Power Company's Response to the First Production Request of the Commission Staffto ldaho Power Company. Also enclosed are four (4) copies of a confidential disk containing information responsive to the Staff's production requests. Very truly yours, Jt'$U-- Julia A. Hilton JAH:csb Enclosures 1221 W ldaho St. (83702) P.O. Box 70 Boise, lD 83707 JULIA A. HILTON (lSB No. 7740) ldaho Power Company 1221 West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-61 17 Facsimile: (208) 388-6936 ih ilton@ida hopower. com Attorney for ldaho Power Company DANIEL E. SOLANDER (lSB No. 8931) Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Telephone: (801 ) 220-4014 Facsimile: (801 ) 220-3299 dan iel. solander@pacificorp. com Attorney for PacifiCorp IN THE MATTER OF THE APPLICATION OF PACIFICORP DBA ROCKY MOUNTAIN POWER AND IDAHO POWER COMPANY FOR AN ORDER AUTHORIZING THE EXCHANGE OF CERTA! N TRANSMISSION ASSETS COMES NOW, ldaho Power Company ?r1F Ft'l 2:r L: 28 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NOS. IPC.E.14-41 PAC-E-14-1 1 IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY ("ldaho Powe/' or "Company"), and in the Commission Staff to ldaho Powerresponse to the Company dated First Production Request of February 4,2015, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 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 ldaho Power Company? RESPONSE TO REQUEST NO. 1: ldaho Power does not directly assign or allocate all operations and maintenance ("O&M") costs to specific plant in service for which those costs are applicable. Of the tracked expenses, the average monthly maintenance expenses directly related to the lines to be transferred is $10,300. The average tracked monthly maintenance expenses directly related to the stations to be transfened is $67,000. The response to this Request is sponsored by Paula Penza, Finance Team Leader, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 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 transfened to ldaho Power Company from PacifiCorp? RESPONSE TO REQUEST NO. 2: The monthly O&M expenses associated with the transfer of plant in service from PacifiCorp, dlbla Rocky Mountain Power ("PacifiCorp") to ldaho Power are estimated as follows: Estimated Monthlv Billine IDAHO Lines-O&M Stations-O&M s $ 67,zfi lLilTs Tota! Btamated Monthly Lines and Stations O&M Billing s 78,395 The response to this Request is sponsored by Paula Penza, Finance Team Leader, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 REQUEST NO. 3: Will there be any financial gain or loss associated with the transfer of assets? lf so, please provide the specific details and associated assets. RESPONSE TO REQUEST NO. 3: Please refer to PacifiCorp's response to the ldaho Public Utilities Commission Staffs Request No. 3 to PacifiCorp. The response to this Request is sponsored by Paula Penza, Finance Team Leader, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 REQUEST NO. 4: Please provide the proposed joumal entries associated with the transfer of assets. RESPONSE TO REQUEST NO. 4: Idaho Powe/s and PacifiCorp's respective proposed journa! entries were included within the joint Federal Energy Regulatory Commission ("FERC') 203 filing in Docket No. EC15-54-000. Specifically, Attachment 1 on page 329, which can be accessed at: http://elibrarv.ferc.oov/idmws/common/OpenNat.asp?filel D=1 371 7306. The response to this Request is sponsored by Courtney Waites, Senior Regulatory Analyst, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 REQUEST NO. 5: Please quantify the financia! benefits to ldaho Power customers for the transparency, flexibility, and reliability accomplished by this asset transfer. RESPONSE TO REQUEST NO. 5: While ldaho Power and PacifiCorp have not quantified the total amount of time and cost dedicated to resolving differences in interpretation of the Legacy Agreements, the companies have dedicated significant executive, legal, operational, technical, and regulatory resources toward managing both the ongoing administration of the Legacy Agreements and associated interpretation questions. For example, from an operational perspective, daily administration (i.e., scheduling/tagging) of the Legacy Agreements can take up to four hours and after-the- fact reconciliation can take up to 10 hours per month, which is significantly more time and labor than required to perform similar tasks for modern contracts. These examples exclude time spent by other departments, as well as operations, in trying to manage and resolve differences in interpretation, which have occasionally required up to 30 hours or more in one week to address. The companies have also incuned significant Iegal expenses over the years related to interpretation of the Legacy Agreements. The elimination of these activities will result in avoided administrative costs; however, the specific amount of costs avoided has not been estimated. The response to this Request was prepared by Kathy Anderson, Transmission Energy Scheduling Leader, ldaho Power Company, under the direction of Lisa Grow, Senior Vice President of Power Supply, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 REQUEST NO. 6: What future anticipated projects, including capital, maintenance, and operational, will no Ionger 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. RESPONSE TO REQUEST NO. 6: As stated in David Angell's direct testimony, this transfer of assets will eliminate the need for the tap of the Brady - Antelope 230 kilovolt ("kV") transmission line, the Iine from that tap to the Haven substation, and the upgrade of the distribution feeder, Portneuf 042, lhat presently serves the Arbon Valley customers. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCT]ON REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7 REQUEST NO. 7: Please provide a schedule showing the plant in service by specific plant account, original cost, cunent book value, current depreciation expense and accumulated depreciation for the assets to be transferred to PacifiCorp. RESPONSE TO REQUEST NO. 7: Please see the attached asset sheet. The response to this Request is sponsored by Larry Tuckness, Finance Team Leader, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8 REQUEST NO. 8: The Joint Purchase and Sale Agreement (JPSA) requires ldaho Power to be responsible for the 230 kV Upgrades necessary to provide PacifiCorp with 510 MW of long{erm firm point-to-point transmission service on ldaho Power's transmission system. (Application, JPSA, pg. 27, Section 2.g(bXxiv).) 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. RESPONSE TO REQUEST NO. 8: The 230 kV upgrades are identified in Schedule 1.1(k) of the JPSA and repeated here: (1) install a2301138 kV, 300 megavolt ampere transformer at the Bowmont substation and (2) replace two 230 kV series capacitor banks at the Midpoint substation. These upgrades wil! increase the capacity of the ldaho Power Midpoint West transmission path rating from 1027 megawatts ("MW") to 1300 MW. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, ldaho Power Company. ]DAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9 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 Dl, 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 ldaho Powe/s Balancing Authority Area. RESPONSE TO REQUEST NO. 9: ldaho Power follows the scheduling time lines outlined in its Open Access Transmission Tariff ('OATT') for all service sold under the OATT. This allows all schedules to be presented to ldaho Power for processing no later than 20 minutes before the start time of the schedule. This includes any inter-hour schedules that begin at xx:15, xx:30, or xx:45. All automatic validations for schedules in ldaho Powe/s scheduling systems are set to accept this timing. The services provided under the Legacy Agreements currently in place with PacifiCorp have different timing requirements. They require schedule changes to be done no later than 30 minutes before the top of the next hour. lt does not allow for any intra-hour changes to these schedules, except for forced generation or transmission outages that affect the schedule. This requires manual monitoring and intervention of schedules to ensure these schedules are handled according to the contract. Under the proposed JOOA, these schedules become OATT schedules and are processed like all other OATT schedules with regard to timing. This allows for all the automatic validations in the IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1O systems to be applied to all schedules and eliminates the manual intervention and monitoring. With regard to dynamic transfer capability, the generatlon that is allowed to use the dynamic transfer capacity is limited to a specific generator in the current Legacy Agreements. In addition, the contracts further restrict how much that scheduled generation transfer can vary from the before the hour schedule to the final after the hour adjusted schedule. This creates a manual process after the hour to ensure the adjustments made to the schedules are within the terms of the contract. lt does not allow for intra-hour dispatching of the resource. Under the OATT service, the restriction on what resources can utilize that dynamic capacity is eliminated and current North American Electric Reliability Corporation ("NERC"), North American Energy Standards Board, and Western Electricity Coordinating Council (.WECC') standards regarding schedule changes would apply to these schedules rather than specific contract limitations. As the industry continues to implement and utilize intra-hour scheduling and develops energy imbalance markets, it becomes more important to standardize and automate the processing of schedules. By eliminating the non-standard schedules and restrictions of use in the current Legacy Agreements, it better aligns ldaho Power to automate the processing of schedules. The response to this Request was prepared by Kathy Anderson, Transmission Energy Scheduling Leader, ldaho Power Company, under the direction of Lisa Grow, Senior Vice President of Power Supply, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY . 11 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. RESPONSE TO REQUEST NO. 10: Section 6 of the Restated Transmission Service Agreement ("RTSA") outlines how losses are repaid for the services provided under the contract. Under Section 6, the Iosses PacifiCorp is required to repay to ldaho Power for use of its system under the RTSA is determined by: 2.8 percent of the hourly incremental amount of the total net scheduled transfers (for RTSA allowed services) that are less than or greater than 1,000 megawatt-hours per hour, except to the extent that such transfers are below 1,000 megawatts for at least two (2) hours due to a forced outage, mechanical restriction, or scheduled maintenance outage at the Jim Bridger Project, on the Bridger Transmission System, on the ldaho Power transmission system or on PacifiCorp's Midpoint-Summer Lake 500 kV transmission line, any of which directly force a Party to reduce the East to West Transfer Services in order to maintain system reliability. The RTSA also defines loss repayment for transmission and generator main step-up transformer Iosses. Section 6.3 of the RTSA discusses how these losses are distributed between ldaho Power and PacifiCorp. ldaho Power and PacifiCorp are currently reviewing options for the loss calculations and repayment options but have not yet determined a common methodology. !t is anticipated a common methodology will be completed by the closing date of the transaction. The response to this Request was prepared by Kathy Anderson, Transmission Energy Scheduling Leader, ldaho Power Company, under the direction of Lisa Grow, Senior Vice President of Power Supply, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12 REQUEST NO. 11: Please provide copies of the Phase 1, and if available the Phase ll, Environmental Site Assessments for the properties proposed to be transferred to PacifiCorp underthe JPSA. RESPONSE TO REQUEST NO. 11: ldaho Power proposes to transfer only equipment, not land, to PacifiCorp under the JPSA. Because no land is being transferred under the JPSA, there are no Phase I and Phase ll Environmental Site Assessments that pertain to the JPSA transaction. The response to this Request is sponsored by Lisa Grow, Senior Vice President of Power Supply, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13 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. RESPONSE TO REQUEST NO. 12: The following FERC accounts were used in the calculations presented in Exhibit No. 1 of Lisa Grow's testimony: Electric Plant ln Service (101) 350 352 3s3 354 355 356 3s9 362 394 397 398 Accumulated Provision for Depreciation (108) 350 3s2 353 354 355 356 3s9 352 394 397 398 Accumulated Deferred Operating Taxes Revenues 282.L 454 456 o&M Depreciation Expense (403) Deferred lncome lncome Tax Tax 569 570 924 350 352 3s3 354 355 355 359 362 394 397 398 4LO.L/41L.1 4O9.L The response to this Request is sponsored by Lisa Grow, Senior Vice President of Power Supply, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14 REQUEST NO. 13: How will the asset exchange impact the current Power Cost Adjustment (PCA) and/or Fixed Cost Adjustment (FCA) mechanisms? RESPONSE TO REQUEST NO. 13: Based on current known information, ldaho Power anticipates a slight reduction in FERC Account 565, Third Party Transmission, expenses upon execution of the JOOA with PacifiCorp. Because Account 565 expenses are tracked through the PCA mechanism, any benefits associated with the reduction in expenses will flow through to customers annually through the PCA. The asset exchange will have no immediate impact on the FCA mechanism. However, any changes in the Company's fixed costs that are a result of the asset exchange would be reflected in ldaho Powe/s FCA mechanism following the next general rate case. The response to this Request was prepared by Courtney Waites, Senior Regulatory Analyst, ldaho Power Company, under the direction of Lisa Grow, Senior Vice President of Power Supply, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15 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. RESPONSE TO REQUEST NO. 14: While overall transmission O&M expenses are expected to remain the same, the transmission O&M expenses that will be charged pursuant to the JOOA (FERC Accounts 567,570, and 571) are expected to be lower as a result of the proposed transaction because current "use of facilities" expenses (FERC Account 454) will be replaced by ownership on certain transmission paths. Please refer to the confidential Excel spreadsheet provided in the Company's response to the lndustrial Customers of ldaho Powe/s ('lClP") Request for Production No. 21(a) which details the change in transmission O&M expenses as a result of the asset exchange. The analysis presented as Exhibit No. 1 to Lisa Grow's direct testimony demonstrates that there is a net increase in third-party transmission revenue (FERC Account 456) if the asset exchange is approved. As described on page 17 of Lisa Grow's direct testimony, "upon termination of the MTFA, RTSA, and ITSA, the associated contract demands used in the calculation of ldaho Powe/s OATT formula rate will become zero." This change will result in an increase to ldaho Powe/s third- party transmission rate, which is projected to translate into higher third-party transmission revenues. The response to this Request was prepared by Kelley Noe, Financial Analyst, ldaho Power Company, under the direction of Lisa Grow, Senior Vice President of Power Supply, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16 REQUEST NO. 15: 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 Dl, pg. 11, lines 3-6.) Further, please clarify if these eastbound rights will primarily add redundancy, or serve future land growth. RESPONSE TO REQUEST NO. 15: The above-referenced section of David Angell's direct testimony pertains to off-system sale of firm Jim Bridger energy. The 100 MW of eastbound rights are within the Jim Bridger transmission system, which includes the following facilities: Borah; Kinport; Populus; Goshen; Three Mile Noll; and Jim Bridger substations, Borah - Populus #1, Kinport - Populus, Populus - Jim Bridger #1, Populus - Jim Bridger #2, Kinport - Goshen, and Goshen - Jim Bridger. The potential customers of the Jim Bridger energy are electric utilities, including any power marketing function, federal power marketing agencies, or any entity purchasing energy for resale. Assuming a firm energy sale, the load locations would be specific to the customer acquiring the Jim Bridger energy. ln addition to the Jim Bridger energy sales, the capacity will be managed through the OATT and any of the potential customers identified above could request and contract transmission service, when available, that may use this path to deliver any energy resource to any load. The eastbound rights do not add redundancy or support future ldaho Power retail Ioad growth. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17 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 Dl, pg. 12, lines 13-17.) RESPONSE TO REQUEST NO. 16: Lines 16 and 17 of Dave Angell's direct testimony incorrectly stated that "eliminating the need for the Brady - Antelope 230 kV line at half the cost of the present plan." It should have stated "eliminating the need for the tap of the Brady - Antelope 230 kV line at half the cost of the present plan." The cost estimates for the Brady - Antelope 230 kV line tap, Atomic City substation, and the line from the Atomic City substation to the Haven substation Goshen - Antelope 161 kV tap, tap substation, and transmission line to Haven substation are on tabs "HAVN 161kV Source" and "Atomic City Station," respectively, of the confidential spreadsheet provided on the confidential CD. The confidential CD will only be provided to those parties that have executed the Protective Agreement in this matter. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMM]SSION STAFF TO IDAHO POWER COMPANY - 18 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. RESPONSE TO REQUEST NO. 17: The Blackfoot, ldaho, area is served by 161 kV and 138 kV transmission lines through two substations, Blackfoot and Pingree, that transform the voltage to 46 kV sub-transmission, which then serves 15 distribution substations. The peak demand for the Blackfoot area occurred on July 1 , 2013, when the total demand reached 160 MW. The load growth forecast for the area is provided in the confidential Exce! file (Attachment 1) provided on the confidential CD. This area load forecast is comprised of the load growth rates for the 15 distribution substations as shown below. Substation Historical Growth Rates Substation Growth Rate Substation Growth Rate AIKN 0.75o/o MRLD 0.50% AMPT 0.50%MSPE 0.50% BKFT 1.00%PNGE 0.90% CNDR 0.50%RKFD 0.75o/o FTHL 0.75o/o RSFK 0.50% HAVN 0.50%SRLG 1.00o/o HULN 0.50%TABR 0.50% LAVA 0.75o/o Please refer to the confidential documents (Attachments 2 through 15) provided on the confidential CD which provide 14 substation area confidential studies in support of the load growth forecast. Additionally, please refer to the confidential document (Attachment 16) provided on the confidential CD which provides the 2014 "Ten-Year Transmission Reliability Assessment 2015-2024" study, in draft form. Section 3.2 (page 12\ and Section 6, IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19 Table 6.1 (page 29) of the study identify the Blackfoot - Goshen 161 kV line outage and resulting overload of Don - Pingree Junction 138 kV line section along with a proposed solution to tap the existing Antelope - Goshen 161 kV line included in the asset exchange. The Antelope - Goshen 161 kV tap and line to Haven will need to be in place prior to an overload of the Don - Pingree Junction 138 kV line section. Based on project permitting time frames, ldaho Power anticipates that the project may be constructed and placed in-service by 2020, which should coincide with near 100 percent load of the Don - Pingree Junction 138 kV line section. The confidential CD will only be provided to those parties that have executed the Protective Agreement in this matter. The response to this Request is sponsored by David Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20 Customer 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 Dl, pg. 13, lines 23-24.) RESPONSE TO REQUEST NO. 18: The cost for a typical 138 kV class substation of the size necessary to serve the Arbon Valley area is $1.8 million. An additional $300,000 would be required to fully integrate the substation, for a total cost of $2.1 million. Please refer to the confidential Excel file provided on the confidential CD for the cost estimate to rebuild the existing distribution feeder. The confidential CD will only be provided to those parties that have executed the Protective Agreement in this matter. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21 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. RESPONSE TO REQUEST NO. 19: The Arbon Valley customers are served by Portneuf 42, a 34.5 kV distribution feeder that originates at the Portneuf substation near the town of Portneuf, Idaho. Please refer to the Portneuf 42 distribution feeder section of the confidential PDF provided on the confidential CD, the Portneuf small area study, for the area load forecasts that include the Arbon Valley load. The area load forecast is broader than the Arbon Valley; therefore, the recent change in Arbon Valley retail customer count is provided in the table below as additional supporting evidence of Ioad growth. The response to this Request is sponsored by David Angel!, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 22 Arbon Vallev Customer Count at the End of Each Given Year 2009 2010 2011 2012 2013 2014 196 201 206 211 213 218 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 Dl, pg. 15, lines 22-23.) RESPONSE TO REQUEST NO. 20: The proposed asset exchange does not eliminate the need for additional transmission investments. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 23 REQUEST NO. 21: Please provide supporting data for cunent transmission use by retai!, wholesale, and generation customers served by ldaho 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 D!, pg. 17, lines 2-18.) RESPONSE TO REQUEST NO. 21: Idaho Power does not have and is not acquiring any westbound Hemingway - Summer Lake 500 kV line ownership. The response to this Request is sponsored by David Angel!, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24 REQUEST NO. 22: Please provide an explanation of how the Bonneville transmission wheeling expense will be reduced or eliminated from ldaho Powe/s acquisition of the Walla Walla - Hurricane transmission line. (Application, Angel Dl, pg. 18, lines 24, 18-19.) RESPONSE TO REQUEST NO.22: The existing ownership and capacity rights result in both a Bonneville Power Administration ('BPA") and PacifiCorp wheeling expense when ldaho Power imports energy from the Mid-C market through the Walla Walla - Hurricane transmission line. David Angell's direct testimony refers to the elimination of only the PacifiCorp transmission wheeling expense (the BPA wheeling expense will remain) when the Wa!!a Walla - McNary line is constructed and Idaho Power exercises the option to participate in the construction. These components will provide ldaho Power with uninterrupted capacity ownership from Hurricane, ldaho Powe/s existing boundary, to BPA's McNary substation. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 25 REQUEST NO. 23: What are the estimated changes to the ldaho-Northwest path ratings following the anticipated Walla Walla Hurricane Iine upgrades? (Application, Angel DI, pg. 18, lines 12-14.) RESPONSE TO REQUEST NO. 23: David Angell's direct testimony references upgrades to the ldaho to Northwest path rather than the Walla Walla - Hurricane line itself. These conceptualized upgrades have not been modeled and analyzed to an extent to estimate a change to the ldaho to Northwest path rating. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 26 REQUEST NO. 24: Please explain whether ldaho Power is currently prepared to implement an Energy lmbalance Market or Security Constrained Economic Dispatches, or whether there are specific areas within ldaho Powe/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. RESPONSE TO REQUEST NO. 24: ldaho Power is an active participant in the Northwest Power Pool MC lnitiative, which is looking at the development of a Security Constrained Economic Dispatch ("SCED") model for that footprint. ln preparation for a SCED or energy imbalance market ("ElM"), ldaho Power has entered into a professional services agreement with a consulting company to perform a detailed EIM impact assessment to provide a better understanding of the potential impacts of participating in the proposed Northwest Power Pool SCED Market. The contractor will assess the potential impacts to ldaho Powe/s existing technology, business processes and organizational structure, document the major gaps, and develop a roadmap for resolving those gaps. The project is currently in progress and is anticipated to be complete by March 2015. At that time, ldaho Power will have a better understanding of the gaps needed to overcome prior to entering any SCED or ElM. The proposed acquisition of assets provides additional access to resources in the Northwest, eliminating some of the additional wheeling charges Idaho Power is subject to today. The asset swap also provides Idaho Power an opportunity to participate in IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 27 transmission upgrades as an owner and further increasing the ability to participate in Northwest markets without incurring additiona! wheeling charges. The response to this Request is sponsored by Lisa Grow, Senior Vice President of Power Supply, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 28 REQUEST NO. 25: PIease explain whether the asset exchange will cause any increases or decreases in retai! customer rates. RESPONSE TO REQUEST NO.25: As stated on page 19 of Lisa Grow's direct testimony, "Commission approval of the Legacy Replacement will have no immediate retail customer rate impact for Idaho Power. A change to the revenue credit used to offset retail customer rates will occur when the Company files its next general rate case." The date of such a filing is unknown. The response to this Request is sponsored by Lisa Grow, Senior Vice President of Power Supply, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.29 REQUEST NO. 26: The JPSA includes Planned Improvements (Application, JPSA) to be completed by both ldaho 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. RESPONSE TO REQUEST NO. 26: No planned improvements wil! impact path rating or the flexibility of transmission transfers. There are three planned improvements that will result in impact to transmission capacity as described in the table below. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 30 Planned lmprovement Transmission Capacitv lmpact 8ORA150001 - BORA Replace C341 Series Capacitor The parties plan to replace the existing series capacitor with a higher capacity series capacitor to match the transmission line conductor caoacitv. KPRT150005 - KPRT Replace C341 Series Capacitor Bank The parties plan to replace the existing series capacitor with a higher capacity series capacitor to match the transmission line conductor caoacitv. T601130001 - T601 Goshen-State Line FAC008 Compliance The parties plan to replace the existing conductor with a higher capacity conductor in the Goshen substation to Jefferson substation line section, which will increase the capacity of only that line section. REQUEST NO. 27: Please provide the current OATT formula Exce! spreadsheet and calculations, and the anticipated revised OATT formula Excel spreadsheet as a result of the elimination of the various legacy agreements. RESPONSE TO REQUEST NO. 27: ldaho Power's current OATT rate calculation is publicly available and located on ldaho Power's Open Access Same-time lnformation System at: http://www.oatioasis.com/IPCO/IPCOdocsffransmission Rate October 1 2014- Sept 30 2015 Final lnformational Postino.xlsx ln the confidential Excel spreadsheet provided in the Company's response to lClP's Request for Production No. 7(a), the tab labeled "Trans Revenue Assumptions" contains ldaho Poweds analysis of the estimated impact of future OATT formula rates if the transfer of assets is approved. The response to this Request was prepared by Kelley Noe, Financial Analyst, ldaho Power Company, under the direction of Lisa Grow, Senior Vice President of Power Supply, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 31 REQUEST NO. 28: Please provide supporting data for current transmission use by retai!, wholesale, and generation customers served by ldaho Powe/s 161 kV transmission line between Goshen and Jeffercon. RESPONSE TO REQUEST NO. 28: ldaho Powe/s Load Serving Operations group has a firm 87 MW transmission reservation on the above-referenced transmission path. Please see the attached transmission reservation detail, OASIS reference number 76866224. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 32 REQUEST NO. 29: Please provide a copy of the responses submitted to the Western Electricity Coordination Council (WECC) for the 2014 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. RESPONSE TO REQUEST NO. 29: Please see the attached documents for ldaho Powe/s responses to parts one, two, and three of WECC's 2014 Operational Practices Survey. ldaho Power has revised operational practices to include a realtime contingency analysis improving situational awareness. ldaho Power does not anticipate revising its Operations Practices as a result of the proposed asset exchange. The response to this Request was prepared by Jared Ellsworth, System Planning Engineer, ldaho Power Company, under the direction of David Angell, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 33 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. RESPONSE TO REQUEST NO. 30: The JOOA sets forth the obligations of each party in its role as both owner and operator with respect to compliance with Governmental Requirements and Governmental Authorizations. Govemmental Requirements and Governmental Authorizations, which include federal and state laws, rules, and regulations, are defined terms in Article 1 of the JOOA. The obligations of each party with respect to Governmental Requirements and Govemmental Authorizations as operator are set forth in Article lV of the JOOA. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, Idaho Power Company, in consultation with Julia Hilton, Corporate Counsel, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 34 REQUEST NO. 31: Please explain how the Parties cunently 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. RESPONSE TO REQUEST NO. 31: Because of the joint ownership of the Jim Bridger power plant and the contractual anangements between ldaho Power and PacifiCorp for transmission seryice, planning for these facilities has been and will continue to be conducted cooperatively and, where relevant, related system studies are shared to enhance planning and operational coordination between the utilities. ldaho Power and PacifiCorp, as Transmission Operators, must comply with all requirements of NERC Reliability Standards, which include requirements for coordinating with neighboring Transmission Operators. ln addition, WECC base cases are utilized by both ldaho Power and PacifiCorp to mode! the electrical system for study purposes, and both utilities contribute to the development of these cases. The proposed purchase and sale will not change either ldaho Powe/s or PacifiCorp's interest in or commitment to coordinated planning. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 35 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. RESPONSE TO REQUEST NO. 32: ldaho Power and PacifiCorp, as Transmission Operators and Transmission Planners, must comply with all requirements of NERC Reliability Standards, which include requirements for coordinating with neighboring Transmission Operators on outages and protection system changes (relay settings). ldaho Power and PacifiCorp, as Transmission Planners, must comply with all requirements of NERC Reliability Standards, including the sharing of planning assessments, which contain simulations of impacts of remedial action schemes. Following the proposed asset exchange, the utilities will continue to comply with the NERC Reliability Standards. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, ldaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 36 REQUEST NO. 33: Please explain how the asset exchanges and upgrades to the Idaho - Northwest Transmission (Hemmingway - Summer Lake 500 kV, Walla Walla - Hurricane 230 kV, and Midpoint - Hemmingway 500 kV) and associated substations revise the costs and benefits of the proposed Boardman to Hemmingway transmission expansion. RESPONSE TO REQUEST NO. 33: There are no anticipated changes to the costs and benefits of the proposed Boardman to Hemingway project. The response to this Request is sponsored by David Angell, Customer Operations Planning Manager, ldaho Power Company. DATED at Boise, Idaho, this 25th day of February 2015. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 37 Attomey for ldaho Power Company CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 25th day of February 20151 served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Daphne Huang Deputy Attomey General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, ldaho 83720-007 4 PacifiCorp Daniel E. Solander Rocky Mountain Power 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 lndustrial Customers of ldaho Power Peter J. Richardson RICHARDSON ADAMS, PLLC 515 North 27h Street (83702) P.O. Box 7218 Boise, ldaho 83707 Dr. Don Reading 6070 Hill Road Boise, ldaho 83703 X Hand Delivered U.S. Mail Overnight Mail FAX Email daphne.huanq@puc.idaho.qov Hand Delivered U.S. Mail Overnight Mail FAX Emai! daniel.solander@pacificorp.com Hand Delivered U.S. Mail Ovemight Mail FAXX Email pete r@ richa rd so nad a ms. com Hand DeliveredX U.S. Mail ,Ovemight Mai! FAXX Email dreadinq@mindsprino.com IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 38 Christa Bearry, Legal BEFORE THE IDAHO PUBLIC UTILITIES GOMMISSION CASE NOS. IPG-E -14-41 and PAC-E -14-11 RESPONSE TO STAFF'S REQUEST NO. 7 Plant: Plant Acct Plant Acct Description Idaho Power Company Assets To PAC Net Book Value Plant Balance Accumulated Reserve Net Book Value 352 353 354 355 356 Structures & Improvements Station Equipment Towers & Fixtures Poles & Fixtures Overhead Conductors, Devices Totals 11.297.137.00 (4.916.078.00) 3,139,604.00 30,168,018.00 16,306,540.00 2,876,300.00 (698,496.00) (8,229,061.00) (5,s 18,556.00) (1, r60,371.00) 2,441,108.00 21,938,957.00 10,787,984.00 1,715,929.00 6.381.059.00 Plant Acct Plant Acct Description 63,787,599.00 Annual Depreciation Accrual Rate (20,522,562.00\ Annual Depreciation Expense 43,265,037.00 352 353 354 355 356 Structures & Improvements Station Equipment Towers & Fixtures Poles & Fixtures Overhead Conductors, Devices Total 2.25o/o 254,185.58 1,242,03133 1.84o/o 1.90o/o 2.77% 57,768.71 573,192.34 277,211.18 79,673.51 BEFORE THE IDAHO PUBLIC UT]LITIES COMMISSION CASE NOS. IPC-E-14-41 and PAG-E-14-11 RESPONSE TO STAFF'S REQUEST NO. 28 OATI webOASIS Page I of I Transm issi on Reservation Detail 7 6866224 CON F I RM E D sar", l!1;f" lE3S Roquest Tvoe Start Stop twltuw teqlGrant Bid Prlco Olfer Prlce Prlce Prico Unlt PCM ,EFF PCO TESALE 101 2-05-0 1 )0:00 PD 2021-01 -01 CO:(X) PS t7 t7 0.000(0.000{$/MW HOUR RESERVEDPathr WIPCO/PACE-IPCC IEFF.IPCO/ ieillce Code llncrement I Clasc TYDo I Period Wndow Subclass YEARLY IYEARLY IFIRM POINT TO POINT I FULL PERIOD FIXED Preconflrmed: Yes I CompetinE: No I Nogotlrtod: No I l{erc Prlortty: t I Affiliats: No Reservation Profile Start Dato Stop Dato MWReq lrIW Grant MWH 8id Prlce Oftrer Prlce 2012-0541 00:00 PD , 202141-0'1 00:00 PS 87 87 I 6612783.00 0.00 I 0.00 Profile Total: I OOtZzgO.OO Tirne!Refelences Queued 2012-04-30 10:58:27 PD Deal uDdated 2015-02-19 05:34:35 PS Sale Re3Donso Posilng Request lmoactec i58 ReassiEnod 74110557 Seller Conftrmed Time 2012-0d-3010:58:27 PD Relat€d CG Ooadline Commonts Statuc I Sellor lReassign it at full tariff rate with full renewal riqhts and oblhations Provldor luodabd Path - SF Custonrer I Provi!ions CG Statur Statu. l{otification Anc€ewlc.-Llnk RolloverWalved Concomltant Eva! FlaE Customec IPCL Soller: lPctl Namo I Name StefanieF lPCo Phone I Phone 2083885466 Fax I Fax E.mall I E.mail sfuhhsm@ldahooower.com https://www.oasis.oati.com/cgi-bin/webplus.dll?script:/woa/woa-tsr-viewtsr-printview.w... 2120/2015 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NOS. IPC-E-14-41 and PAC-E-14-11 RESPONSE TO STAFF'S REQUEST NO.29 2014 Operational Practices Survev The annual Operational Practices Survey is an important toolWECC uses to fulfill its role as the Reliability Assurer in the Western lnterconnection. The WECC Operations Performance Analysis Department conducts the Operational Practices Survey to identiff processes, best practices, and opportunities for improvement and to discern trends by comparing survey responses across years. lndividual responses to the 2014 Operational Practices Survey are confidential and will not be shared with any entity or person other than the submitting entity. WECC may share a list of the entities surveyed and their response status, i.e., has or has not responded. Responses are not shared with the WECC Compliance Department or personnel. Responses to the survey do not constitute a compliance submission or indicate compliance or non-compliance with any Reliability Standard. Please direct questions about the Survey to Tim Reynolds, Reliability Vulnerability Staff Specialist, treynolds@wecc.biz. Part 1: Near-Term Operations: Next-Day Studies This is Part 1 of the 3-part 2014 Operational Practices survey. This part of the survey addresses near- term operations, specifi cally next-day studies. The questions that follow are generally applicable to TOPs, GOPs, RCs, and BAs; however, the applicability of specific questions is indicated. PIease fill out those questions applicable to your company. Fields outlined in red are required. This form and your responses can be saved. When you have completed all of your responses, please submit the form in one of two ways: Automatic Submission 1) To submit electronicalty,lCtrcX flfRel 2) From the pop-up box, select you email method 3) lf you select Desktop EmailApplication (e.9., Outlook), an emailwill be automatically generated. Send the email. Entity Name:ldaho Power Entity Acronym; IPCO Entity Registration Number (NGnl; 51 91 Contact p"oon. Jared Ellsworth ng", System Planning Engineer gr"; ;. jel lsworth@idahopower.com phone: 208-388-6499 Manual Submission Send the completed PDF form to opsu rvev@wecc. biz and reference Operational Practices Survey Response in the subject. Registered Function (select allthat apply) Balancing Authority (BA) Reliability Coordinator (RC) Owner (GO) ransmission Owner (TO) Operator (GOP) ransmission Operator (TOP) Planning Coordinator (PC) ransmission Planner (TP) 2014 Operational Practices Survey Part 1 Page 2 Question 1: Applicable to TOPs and RCs Which of the following do you include in your next-day studies? (Select all that apply) Planned internal transmission/generation outages external (neighboring TOP) transmission/generation outages conditions within appropriate thermal and voltage limits conditions within appropriate thermaland voltage limits stability to identiff stability limits sient stability to identify stability limits analysis of required reactive reserves for defined areas Expected generation reserve commitments lnternal projected loads External projected loads Expected net interchange Modeling and simulation of remedial action schemes NaturalGas supply for generation Other Question 2: Applicable to TOPs and RCs r Day-Ahead Study Engineer(s) compare the planned system outages line/generation/reactive device), with actual outages and determine if SOLs provided day-ahead need to be adjusted for same-day operations. Question 3: Applicable to TOPs Describe how projected load, interchange, and generation are calculated (determined) for input into the next-day studies. light load paths, we assume a general light load distribution that we check times over the course of a year to determine if our models are still accurate. heavy load paths, we assume a load comparable to our alltime system peak performing heavy load studies. By making these assumptions, we are taking a approach. lf it appears that this approach is causing problems, we will load/generation values to match expected values for the next day (factoring the orevious several d and exoected weather How do vou check studies for and data 2014 Operational Practices Survey Part 1 Question 4:Applicable to TOPs Do you validate projected load, interchange, and generation values with actualvalues?Iv"t n*o Page 3 Question 5: Applicable to TOPs Are there sutr100-kV facilities in your transmission system that can adversely impact the Bulk Electric System? Yes (lf Yes, proceed to Question 5.a) No (lf No, proceed to Question 5.b) Question 5.a . Are the facilities modeled in your next-day studies and simulated as contingencies? Ivesflltto. Are the facilities modeled for real-time operations and simulated as contingencies in real- time contingency analyses? Ive{.llro. Are the facilities monitored in real-time for pre- and post-contingency exceedances? Iv"s[xo. \trUhat events would trigger a r+evaluation of the sub-100-kV facilities in your transmission system to determine which facilities would be added or dropped? Question 5.b. Have you performed studies to identiff any sub-100-kV facilities that may have an adverse impact on the Bulk Electric System? Ive{.lruo will only do this if we find N-1 and N-2 issues (thermal overloads, or reactive violations) in our conservative models (high load for heavy-load and liqht load for liqht-load have 69 kV lines in several areas that run electrically parallel to BES lines. ln €ses we have determined these lines wil! never adversely impact the BES Additiona! comments (optional): 2014 Operational Practices Survey Part 1 Question 6:Applicable to TOPs Page 4 No (lf No, proceed to Question 6.b) Question 6.a. ls this the primary way you share next-day studies with your neighboring BAs and TOPs? Iv"'[ruo. Have you confirmed that allyour neighboring TOPs and BAs have access to the Peak RC website? Ives[r.ro' * Hil"lc," |lxr,:::"* stud ies i n other wavs? lf we find that we have an impact on a neighboring TOP, or we believe that the neighboring TOP will have an impact on us, we will coordinate with them Question 6.b How do you share your next-day studies? Question 7:Applicable to TOPs ln reviewing your neighboring TOPs' next-day studies, which of the following applies? (Select One) We review all neighboring TOP next-day studies every day We review some neighboring TOP next-day studies every day We review neighboring TOP next-day studies only if the entity contacts us Other (Explain below) 2014 Operational Practices Survey Part 1 Page 5 Question 8:Applicable to TOPs \Mth regard to how often your next-day studies are updated, which of the following applies? (Select one) l-lW" update our next-day studies daily.t-t We evaluate our next-day studies every day to determine whether the study performed the day prior or another recent "similar day study" needs to be updated. We perform a master study (e.9., seasona! study) and update our next-day study as needed We perform a master study (e.9., seasonal study) but do not update it untilthe next season/year Question 9:Applicable to TOPs and RCs On average, how many buses externalto your system are monitored in next-day analysis simulations for pre.and post-contingency conditions? (Select one) 1-2 34 5-6 >6 None Other (Explain below) Question 10: Applicable to TOPs within your company, receives a copy of your next-day studies? (Select allthat apply) lnternal operators Management Transmission planners Substation operators Relay department Other (Explain below) H E next-day studies are posted to an interna! sharepoint site. Planners and have access to this sharepoint site, and can view day-ahead studies they desire. Planned and unplanned outages are coordinated with our department. The Relay department is involved in the day-ahead study 2014 Operational Practices Survey Part 1 Question 11: Applicable to TOPs Do you receive the RC Next-day Operations Planning Analyses? BVes (lf Yes, proceed to Question 11.a) LlNo (lf No, proceed to Question 11.b) Page 6 Question 11.a With regard to how you use the RC Next-day Assessment, which of the following applies? (Select one) We do not complete our next-day studies untilthe RC Next-day Assessment is reviewed We complete our next-day studies then compare them to the RC Next- day Assessment We review the RC Next-day Assessment but do not compare it to the next-day study We receive the RC Nextday Assessment but do not review it unless requested or noticed by the RC Question 11.b Question 12: Applicable to TOPs lf applicable, have you met with all of the GOPs in your territory to identiff information sharing needs? Not applicable because we have no GOPs Yes No lf no, do you plan to meet with them and when? ldaho Power is a Load Serving Entity that acts as the TOP and GOP. For the bset of generation not owned by ldaho Power that is connected to the ldaho Power Question 13: Applicable to TOPs With regard to the information provided by the GOPs for the next-day studies, which of the following applies: (Select one) Bru the information that is needed is provided within an acceptable timeframe I lsome information provided is adequate but some needed information is omitted [fn" information is incomplete and results in frequent follow-up phone catls or meetings [Otn", (Explain below) 2014 Operational Practices Survey Part 1 Page 7 Question 14: Applicable to TOPs With regard to question 13, in cases where information provided by the GOPs is consistently incomplete, what information is missing? ldaho Power is a Load Serving Entity that acts as the TOP and GOP. Most none ldaho Power controlled generation is wind, which we attempt to forecast through Question 15: Applicable to TOPs, BAs, and RCs Would any of the following make your next-day studies more effective? (Select all that apply) More visibility into neighboring BAs or TOPs Updated tools to perform the next-day studies More training for operators to perform next-day studies Metrics to improve accuracy of the next-day studies Peer reviews of next-day studies for best practices and feedback Other (Explain below) Question 16:Applicable to GOPs Have you ever met with your TOP to identify what information needs to be shared for them to perform next-day studies? Ives [*o Question 17: Applicable to GOPs \ffhich of the following do your next-day assessments address: (Select all that apply) flunit outages Mforecasted generation one day out nforecasted generation for multiple days out Vtr Any current issues with Automatic Voltage Regulators or Power System Stabilizers on any unit Any potential issues with protection systems or remedial action schemes Other (Explain below) single unit with an AVR or PSS issue would not affect the SOLs associated of ldaho Power's lines or transfer paths. next-day study process is very effective as it exists today. Obviously ional visibility, and real-time tools cost make the process more effective 2O14 Operational Practices Survey Part 1 Question 18: Applicable to GOPs \ffhat would make next-dav assessments more effective? Page 8 of the expected (next-day) loop-flow across the ldaho Power system. 2014 Operational Practices Survev The annual Operational Practices Survey is an important tool WECC uses to fulfill its role as the Reliability Assurer in the Western lnterconnection. The WECC Operations Department conducts the Operational Practices Survey to identify processes, best practices, and opportunities for improvement and to discern trends by comparing survey responses across years. lndividual responses to the 2014 Operational Practices Survey are confidential and will not be shared with any entity or person other than the submitting entity. WECC may share a list of the entities surveyed and their response status, i.e., has or has not responded. Responses are not shared with the WECC Compliance Department or personnel. Responses to the survey do not constitute a compliance submission or indicate compliance or non-compliance with any Reliability Standard. Please direct questions about the Survey to Tim Reynolds, Reliability Vulnerability Staff Specialist, trevnolds@wecc.biz. Parl2: Long-Term Operations - Seasonal Studies This is Part2 of the 3-part 2014 Operational Practices survey. This part of the survey addresses long- term operations, specifically seasonal studies. The questions that follow are generally applicable to TOPs, TPs, and PCs; however, the applicability of specific questions is indicated. Please fill out those questions applicable to your company. Fields outlined in red are required. This form and your responses can be saved. When you have completed all of your responses, please submit the form in one of two ways: 1) 2) 3) Automatic Submission To submit electronically, lct-rcx nenel From the pop-up box, selEtT!6[6i6il'imethod lf you select Desktop Email Application (e.9., Outlook), an emailwill be automatically generated. Send the email. Entity Name:ldaho Power Company Entity Acronym; IPC Entity Registration Number (NCR/WGR;:5191 s Gontact percon: Jared Ellsworth Title: Svstem Planninq Enqineer Email: iellsworth@idahopower.com a Phone:2083886499 s Manual Submission Send the completed PDF form to opsu rvey@wecc. biz and reference Operational Practices Survey Response in the subject. Registered Function (select all that apply) Balancing Authority (BA) Reliability Coordinator ( RC) GeneratorOwner (GO) Transmission Owner (TO) Generator Operator (GOP) Transmission Operator (TOP) Planning Coordinator (PC) Transmission Planner (TP) ,/ ,/I T ,/ { { 2O14 Operational Practices Survey Parl2 Page 2 Question 1: Applicable to TOPs, TPs, and PCs Which of the following do you include in your seasonal studies? (Select all that apply) fZeUnneO internal transmission/generation outages expected to last for the majority of the season M eUnneO external (i.e., neighboring TOP) transmission/generation outages expected to last for the majority of the season Voltage stability to identify stability limits Transient stability to identify stability limits Pre-contingency conditions within appropriate thermal and voltage limits Post-contingency conditions within most severe thermaland voltage limits analysis of required reactive reserves for defined areas Expected generation reserve commitments lntemal projected loads External projected loads Expected net interchange Natural Gas supply for generation Relay settings Modeling and simulation of RemedialAction Schemes (Explain) ned External outages are limited to those we are aware of in our neighboring Ps. Question 3: Applicable to TOPs, TPs, and PCs Do vou validate load, i and values actual data? Seasonal forecasts are compared to actuals after{he-fact to improve future forecasts. Question 2:Applicable to TOPs, TPs, and PCs ldaho Power performs light load and heavy load seasonalstudies. For light load studies, projected load is assumed to closely match historical light load For heavy load studies, ldaho Power utilizes a 1 in 20 year peak summer load i.e. ldaho Power onlv exoects the forecast to be exceeded 1 vear in 20 2014 Operational Practices Survey Parl2 Page 3 Question 4: Applicable to TOPs and TPs With what entities do you share adverse or unexpected conditions identified in your seasonal studies? (Select allthat apply) INr"ignuoring BAs f,N"ignooring ToPs f r.r"ignooring PGs f rn" nc Question 5: Applicable to TOPs, TPs, and PCs Do you always perform seasonal studies for shoulder periods? Iv"t E*o not? are continuously studying our transfer paths during peak and shoulder months, , we only provide "seasonal studies" to the NOPSG workgroup on a rotation (every three years for each path). Question 6: Applicable to TPs, PCs, and RCs How do you communicate to appropriate operating personnel information about elements that Question 7: Applicable to TPs, PCs, and RCs How do you manage those elements referred to in question 6 in near-term operational planning studies (e.9., outage studies, day-ahead studies)? (Select allthat apply) MtOentified elements are monitored in realtime l-ltOentified etements are included in Real-Time Contingency Analysis (RTCA) studies fZldentified elements are highlighted in the next-day studies EO', elements are monitored regardless of the seasonal study notn"r (Explain) whv ldaho Power's planning department has a meeting scheduled every-other week to uss Operations and Planning issues. These types of issues may be brought on at time, or communicated by phone at times in-between these biweekly meetings. discussions occur for all extraordinary system conditions that 2014 Operational Practices Survey Part2 Question 8: Applicable to TOPs and TPs Do you consider relay settings in your seasonal planning process? [V"r (lf Yes, proceed to Question 8.a) E *o (lf No, proceed to Question 8.b) Page 4 Question 8.a Do you participate in a regional review of relay and/or RAS scheme implementations and coordination? []ves E*o Question 8.b Question 9: Applicable to TOPs and TPs How do you coordinate your seasonal studies with other groups? (Select allthat apply) A regional or sub regional study group Directly with neighboring TOPs Directlywith the RC Directly with other PCs Ma email without follow-up Other (Explain) Question 10: Applicable to TOPs and TPs How do you utilize seasonalstudies within the company? (Select allthat apply) with the transmission operatorc with management Share with transmission planning with substation operations (explain) Power participates in the NOPSG regional study group. lf necessary, ldaho will coordinate with neighboring TOPs, the RC, and other PCs, however, is not the standard process. studies are available to anyone in the company with a Balancing Area desire/need to know the information. 2014 Operational Practices Survey Part2 Page 5 Question 11: Applicable to TPs and PCs How do you evaluate the impacts of major transmission outages under heavy transfer model the major transmission outage with the system curtailed for the given , and run all of our standard N-1 and Multiple Facility Contingencies to each of ldaho Power's impacted transfer paths temporary SOLs. Question 12:Applicable to TPs, PCs, and RCs How do you evaluate the impact of major transmission outages under heavy transfer conditions on sub-'l00-kV facilities, especially those operated in parallel with the BPS, to identify any potential system cascading risks? ho Power models and evaluates sub-100-kV facilities when necessary. Question 13: Applicable to TPs and PCs How do you ensure that seasonal studies address the interaction of various protection systems, especially special protection systems that are designed to mitigate undesired post-contingent conditions? ldaho Power models the functionality our our SPS and RAS. Question 14:Applicable to TPs and PCs Do you benchmak models against real system conditions and events? fV"r (lf Yes, proceed to Questions 14.a) E*o Question 14.a. Does the benchmark include severe and/or unusual system conditions? f,ves E*o. How do you resolve differences between model results and actual system conditions? ho Power attempts to match our model cases with a real-life timeframe. we notice discrepancies between flows on the lines in the path in the versus real life, we will redispatch generation to achieve the desired . lf this doesn't work, we have looked into adjusting transmission line X, and B values if we can find reasons why these may have changed in vour seasonal studies? 2014 Operational Practices Survev The annual Operational Practices Survey is an important toolWECC uses to fulfill its role as the Reliability Assurer in the Westem lnterconnection. The WECC Operations Department conducts the Operational Practices Survey to identify processes, best practices, and opportunities for improvement and to discern trends by comparing survey responses across years. lndividual responses to the 2014 Operational Practices Survey are confidential and will not be shared with any entity or person other than the submitting entity. WECC may share a list of the entities surveyed and their response status, i.e., has or has not responded. Responses are not shared with the WECC Compliance Department or personnel. Responses to the survey do not constitute a compliance submission or indicate compliance or non-compliance with any Reliability Standard. Please direct questions about the Survey to Tim Reynolds, Reliability Vulnerability Staff Specialist, trevnolds@wecc.biz. Part 3: Situational Awareness, Protection Slstems, Angular Separation, EMS This is Part 3 of the 3-part 2014 Operational Practices survey. This part of the survey addresses situational awareness, protection systems, angular separation, and EMS topics. The questions that follow are generally applicable to TOs, TOPs, GOs, GOPs, BAs, TPs, and PCs; however, the applicability of specific questions is indicated. Please fill out those questions applicable to your company. Fields outlined in red are required. This form and your responses can be saved. When you have completed all of your responses, please submit the form in one of two ways: Automatic Submission Manual Submission Send the completed PDF form to opsu rvey@wecc. biz and reference Operational Practices Survey Response in the subject. 't) To submit electronicalfy,lCf-rcf t enel Entity Name:ldaho Power Company 2) 3) From the pop-up box, select you email method lf you select Desktop Email Application (e.9., Outlook), an emailwill be automatically generated. Send the email. Entity Acronym; IPC Entity Registration Number (NCR/WCR): 5191 Contact person: Jared Ellsworth Titte: System Planning Engineer Email : jellsworth@idahopower.com Registered Function (select allthat apply) Balancing Authority (BA) Reliability Coordinator ( RC) Generator Owner (GO) Transmission Owner (TO) Generator Operator (GOP) Transmission Operator (TOP) Planning Coordinator (PC) Transmission Planner (TP) ,/ ,/ ,/ { ,/ ,/ ,/ Phone:208-388-6499 2014 Operational Practices Survey Part 3 Situational Awareness Question 1: Applicable to TOPs, BAs, GOPs, PCs and RCs Which of the following Reliability Tools do you use for situational awareness? (Select allthat apply) RTCA Real-time Line Outage Distribution Factor (LODF) calculations SCADA realtime displays and overview State estimation Real-time voltage stability analysis Real-time transient stability analysis Alarm Tools Signal error detection for both analog and digital inputs (e.9. heart beat) Power Flow Other (Explain) Question 2: Applicable to TOPs, BAs, GOPs, and RCs For which of the following analyses do you rely on another entity to perform? (Select allthat apply) Page 2 RTCA Real-time Line Outage Distribution Factor (LODF) calculations SCADA realtime displays and overview State estimation Real-time voltage stability analysis Real-time transient stability analysis Alarm Tools Signal error detection for both analog and digital inputs (e.9. heart beat) Power Flow Other (explain) The PEAK RC performs an RTCA check of our system. On rare occasions these results will uncover something that improves our situational awareness. The majority of the time there is an issue with the mode! (and in most cases we have already provided data to correct the model issues but the PEAK RC has yet to E { {: {: T / ,/ 2014 Operationa! Practices Survey Part 3 Question 3:Applicable to TOPs, TPs, RCs, and PCs Page 3 What is your process to ensure consistency between real-time and planning models in order to maintain accurate netwok models? Our planning department utilizes a conservative approach with their planning models. lf these models have unacceptable results, the model will be trued up to something that is more representative of the near-term system (i.e. adjust load and generation), and the planninq department will restudv usinq the updated model to determine nextg Question 4: Applicable to TOPs, BAs, and RCs Following a contingency on your system, on average, how long does it take the real-time tools to perform an updated analysis of System Operating Limits or other contingency conditions? (Select one) 71. r ,in 2-3 min 4-5 min >5min Question 5: Applicable to TOPs, BAs, and RCs Do you have a procedure for the loss of real-time tools? 8I""", lf yes, do you share the procedure with the RC? !v"" Z*o lf yes, do you share the procedure with all neighboring TOPs? !v"t lf no, please explain. Question 6: Applicable to TOPs and BAs Have you read the WECC Pre- and Post-Contingency Plan Guideline that was approved by the Operating Committee on May 20,2014 (Link)? Yes No atrtr No E*o atr 2014 Operational Practices Survey Part 3 Question 7:Applicable to TOPs and BAs Do you have pre-contingency measures in place? Page 4 Yes No Question 8: Applicable to TOPs and BAs Do you have post-contingency measures in place? Yes No Question 9: Applicable to TOPs, and BAs lf applicable, which of the following do your pre- and/or post-contingency measures consider? (Select allthat apply) Adjustment or re-dispatch of generation to ensure acceptable system performance (operating within Facility Ratings, bus voltage limits, stability limits, and any other SOL or IROLs) while implementing proposed transmission or generation outages Adjustment of generation and interchange schedules to ensure adequate reserves and regulating margins are maintained Z| neOrest or dispatch of reserves as necessary from Reserve Sharing Group, if applicable |7l provision of notification procedures prior to or following a forced outage 7l ruec."sary actions to resynchronize and reconnect to the lnterconnection Actions to determine whether a manual load shed is needed to prevent imminent separation from the lnterconnection, voltage collapse, or other adverse consequence Direct actions to return the system to a secure state following a major system disturbance Other (Explain) Question 10:Applicable to TOPs, BAs, and RCs Which of the following best describes what you consider appropriate post-contingency mitigation actions for an exceedence of the highest available Facility Rating or bus voltage limit (an RTCA exceedence)? (Select all that apply) l_lnOlustlng generation ortransmission as necessary within 30 minutes MRrtorrted responses such as RAS or automatic capacitor switching f]*o action because they are RTCA results, not cunent system conditions Vtr Vtr 2014 Operational Practices Survey Part 3 Page 5 Question 11: Applicable to TOPs and RCs lf a pre- or post-contingency measure is created, do you provide training to your operators to ensure understanding? Yes No (Explain) Protection Svstems Question 12: Applicable to TOPs, TOs, GOPs, and GOs For which of the following do you share overload trip settings with the RC and neighboring TOPs? (Select allthat apply) f rranstormers l/l rr"n"rission lines 17 otn", (Explain) Settings are shared as needed or requested in order to properly coordinate all types of Protection Systems. Typical communication takes place via email, and all correspondence is saved for future reference. Question 13: Applicable to TOs and GOs When calculating relay settings, how do you perform stability studies? Relay settings are calculated by the System Protection Engineering group and made available to the Planning group should they be needed to perform their stability studies. lf the Planning group discovers a stability limitation on a line/path, and relay settings ehanoes are reorired this will he eoordinatcd with lhe Svstem Protcetinn Fnninccrinn E Question 14: Applicable to TOs and GOs How do you coordinate the results with impacted neighboring GOPs, TOPs, BAs, and PCs before the settings are in place? Settings are shared as needed or requested in order to properly coordinate all types of Protection Systems. Typical communication takes place via email, and all correspondence is saved for future reference. Question 15: Applicable to TOs, TOPs, TPs, and PCs What is your process for reviewing the purpose and impact of RemedialAction Schemes/Special Protection Systems in your footprint to ensure they are properly classified, serve their intended purposes, are coordinated properly with other protection systems, and do not have unintended consequences to reliability of the BPS? The purpose and impact of a RAS would be reviewed if there were a major system change (new major transmission line or generator) or modification to the associated ^^+r., -^+i-a A tr^^-+ ^ *aiar arraaaa lt.^,^ :^ .,^-, r:*l^ ^^^.t r^, ^. ,^l. ^ .l^+^il^-l -^.,:^.., ^EHow frequently do you conduct a revieu/'? Reviews of these systems are always ongoing as we continue to study our system and its transmission lines and paths. Adjustments are made from time-to-time. Detailed RAS reviews are generally done while studying their corresponding path in our regiona! stud6 Vtr 2014 Operational Practices Survey Part 3 Question 16: Applicable to TOPs, BAs, and RCs Page 6 Do you have the ability to determine standing angles in real time following a major transmission outage? lf yes, how do you determine that angle? ldaho Power has installed Phasor Measurement Units (PMUs) at various bus locations in our system. Question 17:Applicable to TOPs, BAs, and RCs Do you have the ability to determine expected post-contingency standing angles (in a RTCA or similar tool) in real-time? [] ves E*o ! v"t E*o lf yes, how do you determine that angle? Question 18: Applicable to TOPs and TOs Have you checked the sync-check relays on major transmission paths within the last five years to identify potential issues with phase angle settings?I v"" lf yes, please answer the following questions: . Did you identify phase angle settings that were too conservatively set based on historical performance? Yes No E*o . Did you identify phase angle settings that were too conservatively set based on transmission studies? f v"t E*o. Do you plan to perform this routine sync-check analysis again? |7| V"" lf yes, on what interval? As system topology changes. E*o lf no, when do you plan to perform the analysis? 2014 Operational Practices Survey Part 3 Page 7 Question 19:Applicable to TOPs and BAs Do you have plans in place for reducing angles to within synch-check relay settings to allow prompt reclosing of lines? Mv"t E*o Question 20: Applicable to TOs and GOs Do you have any RemedialAction Schemes (RAS) that are identified by the WECC Remedial Action Scheme Review and Assessment Plan (Link)? Iv"t lf yes, please answer the following questions: . How many RAS have you identified? Seven During each of the following time periods, how many times has any RAS operated? 2013 2013 2013 2013 2014 2014 . Do you have any plans to add another RAS that will be identified by the WECC Remedial Action Scheme Review and Assessment Plan in the next 5 years? Yes No E*o lf no, do you have plans to add a RAS that will be identified by the WECC Remedial Action Scheme Review and Assessment Plan in the next five years? f ves E*o Q1 Q4: Q1: Q2: atr 2O14 Operational Practices Survey Part 3 Enerqv Manaoement Svstems (EMSI Question 21: Applicable to TOPs Page 8 Within in your company, which of the following functions is within the purview of the EMS staff? (Select allthat apply) Network infrastructure Displays/User interface Real-time database Data historian Advanced applications Automatic Generation Control (AGC) Training simulator SCADA - Control Center SCADA- Field Control center hardware support Other (Explain) Question 22: Applieable to TOPs How many of your EMS support staff are dedicated solely to your EMS? 6 people. Question 23: Applicable to TOPs On average, how many years of relevant experience does your EMS staff have? 12years Question 24: Applicable to TOPs Do you rely on vendors for EMS support or event response support? (Please explain) No. We handle EMS support and event response almost exclusively in-house. / / / {,/ ,/ ,/ T,/ ,/ 2014 Operational Practices Survey Part 3 Page 9 Question 25: Applicable to TOPs ln which of the following does your EMS support staff participate? (Select all that apply) NERC Continuing Education Training courses ln-house operations training Job shadowing in the department they support (e.g. dispatch, scheduling) System Dispatch training Substation awareness Factory Acceptance Testing (FAT) Vendor training Other training (explain) Question 26:Applicable to TOPs Which of the following apply to the formal technical training provided to your EMS support staff? (Select allthat apply) Training is provided to new support staff Training is provided to existing staff on a periodic basis Training is conducted by company staff Training is conducted by the vendor Other (explain) Question 27: Applicable to TOPs How old is your EMS (i.e., when did it come online)? 25 years, although we upgraded our EMS vendor to Alstom in2007. Question 28: Applicable to TOPs When was your EMS last upgraded? 2013 Question 29: Applicable to TOPs Do you have plans to update or rgrlace your EMS?[4; E*o' lf yes, what is your timeline? We follow the vendor's roadmap and use it to supplement our own EMS technology roadmap. We update EMS hardware and software applications on a regular basis. ,/ ,/ { { {,/ 2014 Operational Practices Survey Part 3 Page 10 Other Question 30: Applicable to TOPs, GOPs, RCs, TOs, GOs, TPs, PCs, and BAs) What measures could WECC or others take that would help you address gaps in practices regarding the reliable operation of the Westem lnterconnection? The implementation of pseudo ties across the Western lnterconnection needs to become more consistent. Today pseudo ties are implemented in many different ways and without some prescriptive processes and requirements the practices haveo Question 31: Applicable to TOPs and BAs Does your company use synchrophasor data? Yes ln which of the following ways is it used? E*o E*o n Real-time viewing (e.g. alarms, state estimation, etc.) V enalyzing system events M aencnmarking models n Otner (Explain) Do you have plans to use synchrophasor data? (Please explain) Question 32: Applicable to TOPs Do you communicate planned outages to the RC's Coordinated Outage System (COS)? I ves How often? Daily, when necessary. Do you use another process to inform the RC of changes? (Please explain) Question 33: Applicable to TOPs What, if any, suggestions do you have to improve the COS to meet your needs with regard to outage reporting and coordination? Do you communicate planned outages to the RC's Coordinated Outage System (COS)? None. Do you use information in the COS to perform Next-Day studies? Mves E*" 2O14 Operational Practices Survey Part 3 Page 1 1 Question 34: Applicable to TPs and GOs Which of the following documents have you or others in your company read and utilized? (Select allthat apply) Tlc"n"rrting Unit Model Validation Policy (Link) lZGenerating Facility Data, Testing and ModelValidation Requirements (Link) (GO) fZG"n"rrting Facility ModelValidation Requirements (Link, see Appendix A) (GO)t.L.t Mlc"n"r"ting Unit Baseline Test Requirements (Link. see Apoendix B) (GO) Question 35: Applicable to all Registered Entities This year, WECC issued this survey in three parts in an attempt to ease the burden that one large survey created for entities. We would like your input on this approach, as well as any improvements we might make to this process. Please provide your input below. We liked it.