20170406Staff 18-27 to IPC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. IOI77
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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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.8.16.28
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER
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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, but no later
than THURSDAY, APRIL 27,2017 .
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.0r.228.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY I APRIL 6,2017
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. 18: In Staff s Production Request No. 17, Staff asked:
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.
With respect to the routes the Company considered, please include in your response any
permanent or temporary routes.
REQUEST NO. 19: On page 4 of its application, the Company states that peak demand
reached 63 megawatts during the winter of 2007 . On page 22 of its application, the Company
states that the Overhead Distribution option provides only 60 MW of back-up service for the
existing customers. Please clariS whether the Overhead Distribution option would be able to
meet the Company's 63 megawatt peak demand, and if so, explain how.
REQUEST NO.20: On page 20 of its application, the Company states that the
Underground Transmission option would support a build-out demand of 120 MW. Is this the
capacity of the Underground Transmission line alone, or is it the aggregate capacity of both the
existing overhead line and the proposed Underground Transmission line? Please explain.
REQUEST NO. 21: If the Commission were to accept, as base case, either the
Overhead Transmission-Dollar Mountain option or the Overhead Transmission-Downtown
District Transmission option, would the Company proceed with its plans to provide a redundant
transmission line to the Ketchum/Sun Valley area? Please explain.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APzuL 6,2017
REQUEST NO.22: For the Overhead Transmission-Downtown option please provide
the total cost, including right-of-way, broken down by plant/expenditure type. Please provide
depreciable lives (amortizationperiods, if applicable) for the various plant/expenditure types.
Please indicate the amount of capitalized labor included in the costs. The Company's Response
to the First Production Request of the Commission Staff, question 1(f), indicates the cost of the
option will be $18.5 million, plus the right-of-way costs. Would this entire cost be capitalized?
Are there any separate O&M costs? If so, please provide estimates of the O&M costs. Please
provide the effective property tax rate for the applicable area. Is the Company aware of any tax
incentives that would apply to this project? Please provide the Company's estimate of the
revenue requirement impact of this project along with assumptions and a supporting work paper
in Excel with formulae intact. Please indicate if the Company's estimated revenue requirement
is a levelized revenue requirement (level annual revenue over the project life).
REQUEST NO.23: For Underground Transmission-Options TP-I, TP-2, and TP-3,
please separately provide the total cost, including right-of-way, broken down by
plantiexpenditure type. Please provide depreciable lives (amortizationperiods, if applicable) for
the various plant/expenditure types. Please indicate the amount of capitalized labor included in
the costs. What is the cost of the project, including the right-of-way costs? Would this entire
cost be capitalized? Are there any separate O&M costs? If so, please provide estimates of the
O&M costs. Please provide the effective property tax rate for the applicable area. Is the
Company aware of any tax incentives that would apply to this project? Please provide the
Company's estimate of the revenue requirement impact of this project along with assumptions
and a supporting work paper in Excel with formulae intact. Please indicate if the Company's
estimated revenue requirement is a levelized revenue requirement (level annual revenue over the
project life).
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY J APRIL 6,2017
REQUEST NO. 24: For Underground Transmission-Option TP-l, please provide the
following for all rate classes:
a) Number of local customers benefiting from the TP-l Option (as opposed to the
Overhead Transmission-Downtown option), by rate class and town.
b) Weather normalized annual energy (kwh) usage of these benefitting local
customers, by rate class and town.
c) A map showing boundary lines for benefitting customers.
REQUEST NO.25: For Underground Transmission-Option TP-2,please provide the
following for all rate classes:
a) Number of local customers benefiting from the TP-2 Option (as opposed to the
Overhead Transmission-Downtown option), by rate class and town.
b) Weather normalized annual energy (kYfh) usage of these benefitting local
customers, by rate class and town.
c) A map showing boundary lines for benefitting customers.
REQUEST NO. 26: For Underground Transmission-Option TP-3, please provide the
following for all rate classes:
a) Number of local customers benefiting from the TP-3 Option (as opposed to the
Overhead Transmission-Downtown option), by rate class and town.
b) Weather normalized annual energy (k\yh) usage of these benefitting local
customers, by rate class and town.
c) A map showing boundary lines for benefitting customers.
REQUEST NO. 27: In the event that a surcharge applies to local customers, does the
Company have a preferred recovery period (duration of recovery)? Please explain the
justification for the Company's preferred recovery period.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 APRIL 6,2017
b
,vr.\f
day of April2017.Dated at Boise, Idaho, this
Technical Staff: Mike Monison (18-21)
Bentley Erdwurm (22-27)
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THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Camille Christen
Deputy Attomey General
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5 APRIL 6,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF APRIL 2017, SERVED
THE FOREGOING THIRD PRODUCTTON REQUEST OF THE COMMTSSTON
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
BOrSE ID 83707-0070
E-mail: [e-mail]
[e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-mail : oeter(Erichardsonadams.com
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
7IO N 6TH STREET
BOISE TD 83702
E-mail: [e-mail]
E.MAIL ONLY
SIERRA CLUB
ZACK WATERMAN
zack. waterman@ si erraclub. or g
TIM TATUM
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail : [e-mail]
KIKI LESLIE A TIDWELL
3OO LET'ER BUCK ROAD
HAILEY ID 83333
E-mail: [e-mail]
LAURA MIDGLEY
231YALLEY 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: kelsey@kelseyj aenunez.com
MICHAEL HECKLER
3606 N PROSPECT WAY
GARDEN CITY ID 83714
E-mail: [e-mail]
CERTIFICATE OF SERVICE
COXCOM LLC
C/O C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
E-mail: [e-mail]
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CERTIFICATE OF SERVICE