20170127Staff 1-12 to IPC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10177
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
RE ,EIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR A )
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY TO CONTRUCT SYSTEM )
IMPROVEMENTS FOR WOOD RIVER )
VALLEY CUSTOMERS. )
) __________________ )
CASE NO. IPC-E-16-28
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney ofrecord,
Daphne Huang, Deputy Attorney General, request that Idaho Power Company (Idaho Power or
Company) provide the following documents and information as soon as possible, by FRIDAY,
FEBRUARY 17, 2017.
This Production Request is 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.
Please provide answers to each question and supporting workpapers that provide detail or
are the source of information used in calculations. Idaho Power 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. IDAP A
31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JANUARY 27, 2017
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: The Application indicates that the Company determined that the
Overhead Transmission options are not viable. Application at 19-20, Angell Direct at 29-31.
For the Dollar Mountain route, this determination was based on likely opposition, lack of
redundancy, and need for condemnation. Angell Direct at 29. For the Downtown District route,
this determination was based on likely opposition, likely failure to receive permitting from the
City of Ketchum, and on geographical constraints, and likely need for significant condemnation
of private property. Application at 19-20, Angell Direct at 30-31. The Application indicates that
the Overhead Distribution option is now considered the base case option. Application at 21-22.
a) Please provide additional detail regarding the determinations that the Overhead
Transmission options are not viable and why and how they were made. Please
include any documentation of the decisions and any information, studies or analysis
on which the determinations were based.
b) When were the Overhead Transmission options determined to not be viable? Please
provide any documentation.
c) Please provide the Company's criteria for deciding that condemnation of private
property makes a project unviable and how were such criteria applied here. Have
these same criteria been applied to other Idaho Power projects?
d) Please provide the Company's criteria for determining that visual impact and local
customer opposition makes a project unviable and how were such criteria applied
here. Have these same criteria been applied to other Idaho Power projects?
e) Please provide details and documentation regarding when and why the Overhead
Distribution option became the base case option, including any studies or analyses.
f) Please describe and provide documentation of the differences between the Overhead
Transmission and Overhead Distribution options described in the Application at 19-
22, including but not limited to any differences in cost, feasibility/viability, required
equipment, and reliability.
g) Has the Company's proposed base case using Overhead Distribution ties been the
subject of either the Company's Community Advisory Committee (CAC) process, or
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JANUARY 27, 2017
any other public forum? If so, please provide a summary of the proceedings and
meeting minutes.
REQUEST NO. 2: Please provide the Company's cost estimates for the Overhead
Transmission-Downtown District route (Application at 19; Angell Direct at 26-27). Please
include electronic workpapers with all formulas and links intact.
REQUEST NO. 3: Please describe the equipment required for the Overhead
Transmission-Downtown District route (Application at 19; Angell Direct at 26-27).
a) Please include the quantities, types, and ratings of transformers, poles, and conductors
considered in its cost estimates for this option.
b) Please provide the Company's estimate of the load that the Overhead Transmission­
Downtown District route could serve in the event that the Company's existing
transmission line were to fail completely.
REQUEST NO. 4: Please describe the equipment required for the Underground
Transmission/TPl option (Application at 20; Angell Direct at 27).
a) Please include the quantities, types, and ratings of transformers, and conductors
considered in its cost estimates for this option.
b) Please describe construction of the underground installation, including installation
depth, splice vaults/and access points, trenches, and duct banks.
c) Please provide the Company's estimate of the load that the Underground
Transmission/TP 1 option could serve in the event that the Company's existing
transmission line were to fail completely.
REQUEST NO. 5: In his direct testimony, Mr. Adelman indicates that Idaho Power has
no experience with underground transmission lines, and that in the event of a cable failure, the
Company would use contractors with underground transmission experience (Adelman Direct at
7).
a) Please provide a list of qualified contractors and where they are located.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JANUARY 27, 2017
b) Does the Company plan to enter into agreements with these companies to ensure that
service is available when required? Please describe the type of agreement and
services required.
REQUEST NO. 6: Has the Company compared the lifecycle costs of maintaining the
proposed TPl Underground Transmission System and the Overhead Transmission system
described on page 19 of the Company's Application? If so please provide such information.
REQUEST NO. 7: Please provide any additional analysis or work in conjunction with
INL regarding locally sited generation resources that is not included in Exhibit No. 3.
REQUEST NO. 8: The Company's Application, at 16, states that the expected duration
of sustained outages will be more than 209 minutes per year with the current transmission
configuration. Please provide information on sustained outages occurring over the previous 36
months including duration, likely cause, and number of customers affected.
REQUEST NO. 9: The Company describes the activities in 2014 of the "updated" CAC
(Application at 9; Angell Direct at 13-14). Please describe the recommendations of the updated
CAC and dates that these recommendations were made.
REQUEST NO. 10: What are the ages of the poles and any other equipment located on
the existing distribution line running parallel to Highway 75 that would be replaced by
transmission poles and other equipment under the Company's proposal for the Common Route?
REQUEST NO. 11: The Company explains that it "generally initiates and constructs a
second transmission source and transformer when a substation peak load is projected to exceed
40 MW." Application at 15.
a) Please provide any documentation of this policy/40 MW criterion and how it has been
applied.
b) How did the Company derive its 40 MW criterion?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 JANUARY 27, 2017
c) Do any other power companies in the United States use similar criteria? If so, please
provide examples.
REQUEST NO. 12: The Company explains that reconstructing the existing
transmission line would entail numerous interruptions to service, and would therefore not be
feasible. Application at 16-17. Did the Company consider the option of constructing a
replacement transmission line parallel to the existing transmission line, using the existing route
and right-of-way, and keeping the existing line in-service during construction, as an alternative
to the Company's proposal or service interruption during transmission line reconstruction? If so,
please provide the Company's analysis and cost estimates. If not, why not?
~
Dated at Boise, Idaho, this 2 ~ day of January 2017.
Camille Christen
Deputy Attorney General
Technical Staff: Mike Morrison (1-8, 11-12)
Bentley Erdwurm (9-10)
i :umisc:prodreq/ipce 16.28djhmmctbeha prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 JANUARY 27, 2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF JANUARY 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER IN CASE NO. IPC-E-16-28, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN E WALKER
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-mail: [e-mail]
MATTHEW A JOHNSON
Wm.FGIGRAY
WHITE PETERSON GIGRA Y
&NICHOLS PA
5700 E FRANKLIN RD STE 200
NAMPA ID 83687
E-mail: m j ohnson@whi tepeterson. com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-mail: [e-mail]
MICHAEL HECKLER
3606 N PROSPECT WAY
GARDEN CITY ID 83714
E-mail: [e-mail]
TIM TATUM
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
POBOX70
BOISE ID 83707-0070
E-mail: [e-mail]
KIKI LESLIE A TIDWELL
300 LET ER BUCK ROAD
HAILEY ID 83333
E-mail: [e-mail]
LAURA MIDGLEY
231 VALLEY CLUB DR
HAILEY ID 83333
E-mail: [e-mail]
SIERRA CLUB
C/0 ZACK WATERMAN DIR
503 W FRANKLIN ST
BOISE ID 83702
E-mail: zack. [e-mail]
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SECRE RY
CERTIFICATE OF SERVICE