20170403Staff 13-17 to IPC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. IOI77
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.
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Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.I6.28
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Camille Christen, Deputy Attorney General, request that Idaho Power Company (Idaho Power or
Company) provide the following documents and information as soon as possible, by MONDAY,
APRIL 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. IDAPA
31.0t.0t.228.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY APRIL 3,2017
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. 13: Please provide cost estimates for the Company's proposed line
route across Dollar Mountain as described on page 19 of the Company's Application. Please
include electronic workpapers with all formulas and links intact.
REQUEST NO. 14: On page 19 of its Application, the Company explains that the
overhead transmission line route through the Ketchum Downtown District would depend upon
the condemnation of private property. Please provide the Company's estimates of condemnation
costs of the Overhead Transmission line route through the Ketchum Downtown District.
REQUEST NO. 15: On page 19 of its Application, the Company explains that the line
route across Dollar Mountain may require condemnation of private property. Please provide the
Company's estimates of condemnation costs for the line route across Dollar Mountain.
REQUEST NO. 16: In case no. IPC-E-95-6, the Company requested that the
Commission amend CPCN No.272 to delete its authorization to construct a new 138 kV
transmission line from the Wood River substation to the Ketchum substation. In its Application,
the Company stated that it had conducted an extensive reassessment of the feasibility and need
for an additional 138 kV transmission, and had concluded that a redundant line was not
necessary. The Company stated that its reassessment included structural, electrical, fire
protection, and avalanche considerations. The Company also stated that its actual 1994-L995
winter peak load was 55.5 MW, and that this was well below the system's summer capacity limit.
For the five year period from2012 through 2016, system peak has averaged 57.9 MW, or a4.3Yo
increase over the 1994-1995 winter peak load. Please answer the following questions:
a) What new information has caused the Company to determine that a redundant 138 kV
transmission line is now needed?
b) Please provide the results of any structural, electrical, fire protection, and avalanche
risks assessments that the Company has used to determine the need for a redundant
line.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APRTL 3,2017
c) Does the Company believe that the 4.3o/o increase in winter peak load is sufficient to
warrant the need for a redundant line?
REQUEST NO. 17: In its Application, the Company indicated that repairing the
existing system could require as many as 40 eight hour power intemrptions. To avoid these
intemrptions, the Company indicated the need for a second transmission line to provide power
while these repairs are made. Did the Company consider any routes that would permit repair of
the existing line without necessarily providing full redundancy? If so, please describe these
routes and provide cost estimates. Please include electronic workpapers with all formulas and
links intact.
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Dated at Boise, Idaho, this 3 day of April2017
lA*il^ llr*o"
Camille Christen
Deputy Attorney General
Technical Staff: Mike Monison (13-17)
i:umisc:prodreq/ipcel6.28djhmmctbeha prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 APRIL 3,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF APRIL 2077,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER IN CASE NO. IPC-E-I6-28, 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]
dockets@ idahooower. com
PETER J RICHARDSON
zuCHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-mail : [e-mail]
MATTHEW A JOHNSON
Wm. F GIGRAY
WHITE PETERSON GIGRAY
& NICHOLS PA
57OO E FRANKLIN RD STE 2OO
NAMPA ID 83687
E-mail: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-mail: [e-mail]
E.MAIL ONLY
SIERRA CLUB
ZACK WATERMAN
zack. waterman@ sierrac lub. or g
TIM TATUM
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
KIKI LESLIE A TIDWELL
3OO LET'ER BUCK ROAD
HAILEY ID 83333
E-mail : [e-mail]
LAURA MIDGLEY
231 VALLEY CLUB DR
HAILEY ID 83333
E-mail: midgley22 I [e-mail]
KELSEY JAE NUNEZ
KELSEY JAE NUNEZLLC
920 N CLOVER DR
BOISE ID 83703
E-mail: [e-mail]
MICHAEL HECKLER
3606 N PROSPECT WAY
GARDEN CITY ID 83714
E-mail : Michael.p.heckler@,gmail.qorn
CERTIFICATE OF SERVICE
COXCOM LLC
C/O C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 8370I
E-mail : tom.arkoosh@arkoosh. com
CERTIFICATE OF SERVICE