20180731IPC to REC 2.1 - 2.17.pdf

SEffi*.
July 31 ,2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-18-07
Petition for Modification of 90/110 Performance Band and Calculation of
O&M Charges for PURPA QFs - ldaho Power Company's Response to
Renewable Energy Coalition's Second Request for Production
Dear Ms. Hanian
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to Renewable Energy Coalition's Second Request for
Production
Also, enclosed are four (4) copies of non-confidential disks containing information
responsive to these production requests.
Very yours,
DONOVAN E. WALKER
Lead Counsel
dwal [e-mail]
DEW:csb
Enclosures
REC T IVE D
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Donovan E. Walker
An IDACORP Company
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
UUC
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RICTIVED
iii i8 ,lUL 3 |Pll L: 3lr
0r.l
IN THE MATTER OF THE PETITION OF
IDAHYDRO, SHOROCK HYDRO, INC.,
J.R. SIMPLOT COMPANY, AND
RENEWABLE ENERGY COALITION FOR
MODIFICATION OF THE 9O/110
PERFORMANCE BAND AND
CALCULATION OF OPERATION AND
MAINTENANCE CHARGES FOR PURPA
QUALIFYING FACILITIES
CASE NO. !PC-E-18-07
IDAHO POWER COMPANY'S
RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND
REQUEST FOR PRODUCTION
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COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to Renewable Energy Coalition's Second Request for Production to ldaho
Power dated July 10,2018, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 1
REQUEST FOR PRODUCTION NO. 2.1: ln response to REC's request number
'1.2, Idaho Power indicated that the workpapers applying the methodology to arrive at
the escalating rates on Table 1 and 2 on Schedule 72 are not available. ldaho Power
produced in Attachment 2 a document with the header "WORKPAPER IDAHO POWER
COMPANY QUALIFYING FACILITIES INTERCONNECTION O&M SCHEDULE
Schedule No. 72" detailing the final results in the table and the inputs used. Please
apply these inputs to the methodology and show how the rates in Table 1 and 2 were
reached.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.1: Renewable Energy
Coalition's ("REC") Request for Production No. 1.2 requested ldaho Power provide the
formula and all inputs that ldaho Power used to arrive at the percentages listed in
Tables 1 and 2 of ldaho Power's Third Revised Sheet No.72-17 .
Attachment 2 provided with ldaho Power's response to REC's Request for
Production No. 1.2 included (1) the document referenced above, which provided the
inputs, and (2) ldaho Public Utilities Commission's Staff's ("Staff") proposed formula for
calculating the escalating rates. Both documents were available in paper form only.
ldaho Power does not have the 1991-vintage spreadsheet that was used in the ultimate
calculation that applied the inputs to Staffs proposed methodology to arrive at the final
amounts used in Tables 1 and 2.
ln an effort to be responsive to this Request, the Company has developed the
spreadsheet provided on the enclosed CD, which produces the results matching
Schedule 72 Tables 1 and 2. Please note that the model used in the spreadsheet is not
identical to the Staff model, but applies similar logic.
The response to this Request is sponsored by Mark Annis, Senior Regulatory
Analyst, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 2
REQUESTFORPRW: !n response to REC's request number
1.3, ldaho Power did not provide updated values for calculation of the appropriate O&M
rate for interconnections 138 kV and above. Please provide the updated values
necessary to perform a calculation for interconnections 138 kV and above.
RESPONSE TO REQUEST PRODUCTION NO. 2.2:When responding to
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION .3
REC's Request for Production No. 1.3, the Company did not have the necessary
information to respond. Subsequently, Staff provided that information, and the Excel
spreadsheet included on the enclosed CD provides the updated values and calculation
of the operation and maintenance ("O&M") rate for interconnections 138 kilovolts ("kV")
and above.
The response to this Request is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
REQUEST FOR PRODUCTION NO. 2.3: Does the Operations and Maintenance
charge cover the cost of replacement facilities once the facilities have reached the end
of their useful life? lf not, who covers the cost of replacement facilities?
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.3: The O&M charge
covers the cost of replacement facilities whenever replacement is needed, regardless of
the useful life assigned to the facilities.
The response to this Request is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 4
REQUEST FOR PRODUCTION NO. 2.4: Please refer to ldaho Power's
responses to REC's Requests for Production Nos. 1.4 and 1.5.
a. Does ldaho Power continue to charge O&M rates on previous
interconnection faci I ities indefin itely?
b. Consider an interconnection agreement with a length of 35 years and that
provides for construction of a facility with a useful life of 32 years. Does the O&M
charge still continue for years 32-35 even though the facility actually constructed is no
longer useful?
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.4:
a. Yes. As described in the Company's response to REC's Request for
Production No. 1.4, the O&M charge is applied to any existing facilities that are
continuing in service because the Company continues to operate and maintain those
facilities.
b. If the original facilities continue to be used beyond the 32-year estimated
life, the O&M charge continues, based on the original cost of the facilities. Please see
Tables 1 and 2 from Schedule 72, which show the rates for years 1-35 and for all years
beyond 35 years.
As discussed in the Company's response to REC's Request for Production No.
2.3, when interconnection facilities fail during the contract period and are replaced, the
O&M charge to the project does not change and the project is not charged for the costs
of the replacement equipment.
The response to this Request is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 5
REQUEST FOR PRODUCTION NO. 2.5: Does ldaho Power charge FERC-
Jurisdictional interconnections under its OATT for actual operations and maintenance
charges or does ldaho Power use the same Schedule 72 formula for recovering
operations and maintenance charges?
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.5: Please see ldaho
Power's answer to J.R. Simplot Company's Interrogatory No. 11.
The response to this Request is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 6
REQUEST FOR PRODUCTION NO. 2.6: For each QF listed in ldaho Power's
Response to J.R. Simplot's Request for Production No. 16, please provide an
itemization of the interconnection facilities that were constructed including:
a. Description of the facilities constructed (i.e. overhead lines, substations,
poles, breakers, meters, etc.)
b. Cost of each facility, and
c. Whether each facility constructed is a transmission facility subject to the
rates in Table 1 of ScheduleT2 (138 kV and 161 kV) or a distribution facility subject to
the rates in Table 2 of Schedule 72 (Below 138 kV)
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.6:The description of
facilities constructed is contained in each Qualifying Facility's ("QF') Generator
Interconnection Agreement. These agreements are voluminous and can be provided
for review at ldaho Power's corporate headquarters. Please contact Tami White at
[phone] or Camilla McClusky at [phone] to arrange.
The cost of each facility that has O&M charges applied, as well as whether they
are subject to the transmission or distribution rate, is included in the Excel file provided
on the enclosed CD.
The response to this Request is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION .7
REQUEST FOR PRODUCTION NO. 2.7: For each QF listed in ldaho Power's
Response to J.R. Simplot's Request for Production No. 16, please provide the original
interconnection costs, the portion of the original interconnection cost that is subject to
the rates in Table 1 of ScheduleT2 (138 kV and 161 kV), the portion of the original
interconnection costs that is subject to the rates in Table 2 of ScheduleT2 (Below 138
kV), and the O&M charges collected per year for each year since 1990.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.7: Please see ldaho
Power's response to REC's Request for Production No. 2.6 for the original
interconnection costs, the portion of the original interconnection cost that is subject to
the rates in Table 1 of Schedule 72 (138 kV and 161 kV), and the portion of the original
interconnection costs that is subject to the rates in Table 2 of ScheduleT2 (Below 138
kV). Please see ldaho Power's response to ldahydro's Request for Production No. 8 for
the O&M charges collected per year for each year since 1990.
The response to this Request is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 8
REQUEST FOR PRODUCTION NO. 2.8: For the last 3 years, please list all
O&M expenses incurred by Idaho Power in the operations and maintenance of ldaho
Power's distribution facilities of below 138 kV including the following information:
a. Description of the expense
b. Date the expense was incurred
c. Cost ofthe expense
d. The O&M expense category from categories listed in ldaho Power's
response to REC's Request for Production No. 1.2 Attachment 1
e. The type of facility upon which the maintenance is performed (i.e.
overhead lines, substations, poles, breakers, meters, etc.)
f. The location of the facility where maintenance is performed
g. Whether the maintenance was performed in an emergent situation and
why it was emergent (i.e. to repair outages resulting from storms, etc.)
h. If the expense was not incurred on an emergent basis, please provide the
date ldaho Power identified the need for maintenance work and the date(s) the work
was actually performed
RESPONSE TO REQUEST PRODUCTION NO. 2.8:
a-c. The Company records O&M expenses for distribution lines below 46 kV in
Federal Energy Regulatory Commission ("FERC") Accounts 580 through 598. Please
see the spreadsheet provided on the enclosed CD for the expenses incurred in the
O&M of ldaho Power's distribution facilities for the time period 2015 through 2017.
d. The data provided in response to subparts a-c are included in the
categories of Attachment 1 provided with the Company's response to REC's Request
for Production No. 1.2 as follows:
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 9
Column A of Spreadsheet Line in Attachment I Provided with the Company's
Response to REG's Request for Production No. 1.2
Account 580000 Line 22 and Line 23 (total distribution operations)
Accounts 58 1 000, 582000,
584000, 585000, 586000,
587000,588000,589000
Line 23 (total distribution operations)
Account 583000 Line 21 and Line 23 (total distribution operations)
Account 590000 Line 27 and Line 28 (total distribution maintenance)
Accounts 592000, 594000,
595000, 596000, 597000,
598000, 598001,599000
Line 28 (total distribution maintenance)
Account 593000 Line 26 and Line 28 (total distribution maintenance)
e. The type of facility upon which the maintenance is performed is
categorized by the FERC system of accounts, as listed below:
Distribution Expenses
Operation
580 Operation supervision and engineering
581 Load dispatching (Major only)
581.1 Line and station expenses (Nonmajor only)
582 Station expenses (Major only)
583 Overhead line expenses (Major only)
584 Underground line expenses (Major only)
584.1 Operation of Energy Storage Equipment
585 Street lighting and signal system expenses
586 Meter expenses
587 Customer installations expenses
588 Miscellaneous distribution expenses
589 Rents
Maintenance
590 Maintenance supervision and engineering (Major only)
591 Maintenance of structures (Major only)
592 Maintenance of station equipment (Major only)
592.1 Maintenance of structures and equipment (Nonmajor only)
592.2 Maintenance of Energy Storage Equipment
593 Maintenance of overhead lines (Major only)
594 Maintenance of underground lines (Major only)
594.1 Maintenance of lines (Nonmajor only)
595 Maintenance of line transformers
596 Maintenance of street lighting and signal systems
597 Maintenance of meters
598 Maintenance of miscellaneous distribution plant
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 1O
The following link to the Code of Federal Regulations provides a detailed
description of the type of expenses recorded to the above FERC accounts:
https://www.ecfr oov/cqi-bin/retrieveECFR?op=&SlD=Oae8a08d6e1697b03b7399'l0eaa5ce06&mc=true&r=PART&n=pt18.1.101.
f-h. ldaho Power does not separately track O&M charges in such a manner.
Please see the Company's response to REC's Request for Production No. 1.11.
The response to this Request is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company, and Mark Annis, Senior Regulatory Analyst, ldaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 11
REQUEST FOR PRODUCTION NO. 2.9: For the last 3 years, please list all
O&M expenses incurred by ldaho Power in the operations and maintenance of ldaho
Power's transmission facilities of 138 kV and 161 kV including the following
information:
a. Description of the expense
b. Date the expense was incurred
c. Cost ofthe expense
d. The equivalent O&M transmission expense category to the categories
listed in ldaho Power's response to REC's Request for Production No. 1.2 Attachment 1
for distribution facilities
e. The type of facility upon which the maintenance is performed (i.e.
overhead lines, substations, poles, breakers, meters, etc.)
f. The location of the facility where maintenance is performed
g. Whether the maintenance was performed in an emergent situation and
why it was emergent (i.e. to repair outages resulting from storms, etc.)
h. lf the expense was not incurred on an emergent basis, please provide the
date ldaho Power identified the need for maintenance work and the date(s) the work
was actually performed
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.9:
a-c. The Company records transmission expenses for transmission lines 46 kV
and above to FERC Accounts 560 through 573. Please see the spreadsheet provided
on the enclosed CD for the expenses incurred in the O&M of ldaho Power's
transmission facilities for the time period 2015 through 2017. ldaho Power does not
track O&M specifically for 138 kV and 161 kV transmission lines.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 12
d. The data provided in response to subparts a-c are included in Line 13
"Total Transmission O&M Expense" of the attachment provided with the Company's
response to REC's Request for Production No. 2.2.
e. Expenses are recorded to the following accounts in the FERC system of
accounts:
Transmission Expenses
Operation
560 Operation supervision and engineering
561.1 Load dispatch-Reliability
561.2 Load dispatch-Monitor and operate transmission system
561.3 Load dispatch-Transmission service and scheduling
561.4 Scheduling, system control and dispatch services
561.5 Reliability planning and standards development
561.6 Transmission service studies
561.7 Generation interconnection studies
561.8 Reliability planning and standards development services
562 Station expenses (Major only)
562.1Operation of Energy Storage Equipment
563 Overhead line expense (Major only)
564 Underground line expenses (Major only)
566 Miscellaneous transmission expenses (Major only)
567 Rents
567.1 Operation supplies and expenses (Nonmajor only)
Maintenance
568 Maintenance supervision and engineering (Major only)
569 Maintenance of structures (Major only)
569.1 Maintenance of computer hardware
569.2 Maintenance of computer software
569.3 Maintenance of communication equipment
569.4 Maintenance of miscellaneous regional transmission plant
570 Maintenance of station equipment (Major only)
570.1 Maintenance of Energy Storage Equipment
571 Maintenance of overhead lines (Major only)
572 Maintenance of underground lines (Major only)
573 Maintenance of miscellaneous transmission plant (Major only)
574 Maintenance of transmission plant (Nonmajor only)
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 13
The following link to the Code of Federal Regulations provides a detailed
description of the type of expenses recorded to the above FERC accounts:
httos://www.ecfr.oov/cqi-bin/retrieveECFR?qp=&SlD=0ae8a08d6e1697b03b73991Oeaa5ce06&mc=true&r=PART&n=pt18.1.101.
f-h. ldaho Power does not separately track O&M charges in such a manner.
Please see the Company's response to REC's Request for Production No. 1.11.
The response to this Request is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company, and Mark Annis, Senior Regulatory Analyst, ldaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 14
REQUEST FOR PRODIIC'ILQN NO. 2.10: For each value ldaho Power
provided in response to REC's Request for Production No. 1.2in Attachment 1, please
provide an itemization of all the expenses that are included within that value.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.10: ldaho Power is
unable to provide itemized expenses for the 1989 timeframe as they no longer exist.
The response to this Request is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 15
REQUEST FOR PRODUCTION NO. 2.11: For each of the categories listed in
the attachmentto ldaho Power's response to REC's Requestfor Production No. 1.10,
please detail what kinds of facilities are included are included in that category and the
dollar value.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.11: Please see the
attachment provided with the Company's response to Staffs Request No. 13, column F,
for a description of the amounts included in each line of the attachment provided with
the Company's response to REC's Request for Production 1.10. The following link to
the Code of Federal Regulations provides detailed descriptions of the types of facilities
and types of expenses included in each category:
https://www.ecfr.qov/cqi-bin/retrieveECFR?qp=&SlD=0ae8a08d6e1697b03b739910eaa5ce06&mc=true&r=PART&n=pt18.1.101 .
The response to this Request is sponsored by Mark Annis, Senior Regulatory
Analyst, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 16
REQUEST FOR PRODUCTION NO. 2.12: Please list the types of facilities
(poles, wires, meters, etc.) that ldaho Power uses in its distribution (below 138 kV)
system. For each facility type, please provide:
a. The total capital cost for all facilities of that type
b. The percentage of the capital cost to the total capital cost for the
distribution system
c. The portion of the capital cost for all facilities of that type that are
constructed pursuant to an interconnection agreement governed by and subject to the
Schedule 72 O&M fees
d. The percentage of the value produced in response to 2.12(c) to the total
for all facilities are constructed pursuant to an interconnection agreement governed by
and subject to the Schedule 72 O&M fees
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.12: In response to
subparts a and b, the following table provides the total capital cost and associated
percentage of the Company's facilities classified as distribution as of December 31,
2017:
Account Account Description 1213112017 Balance Percentage
Land and Land Rights
Structures and lmprovements
Station Equipment
Poles, Towers and Fixtures
Overhead Cond uctors, Devices
Underground Conduit
Underground Conductors, Devices
Line Transformers
Services
Meters
I nstallations, Cust Premises
Street Lighting, Signal System
Asset Retirement Cost-Dist Plt
Total Distribution Plant
$6,052,619.68
37,463,373.49
237,332,108.55
265,381,383.03
136,069,937.48
50,759,070.08
258,499,754.18
560,033,827.33
60,786,068.28
90,021,167.68
3,057,356.02
4,526,920.85
142,630.04
$ 1,710,126,216.69
0.350/o
2.19%
13.88Yo
15.52o/o
7.96Yo
2.97%
15.12o/o
32.75o/o
3.55o/o
5.26%
0.18Yo
0.260/o
0.01o/o
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 17
360
361
362
364
365
366
367
368
369
370
371
373
374
Please note that ldaho Power's transmission assets include some line assets
that are operated at less than 138 kV. The value of those transmission assets is
included within the Company's response to REC's Request for Production No. 2.13.
Regarding subparts c and d, all capita! costs associated with QF interconnection
facilities are to be reimbursed by the project when initially constructed, so those facilities
are recorded at net zero cost and thus not included in the response to subparts a and b.
Any remaining unreimbursed original facilities construction costs and any capital
expenditure to replace these facilities are deemed a part of ldaho Power's plant, the
same as any other plant that is not customer funded and is not uniquely identified or
tracked in the Company's accounting records.
The response to this Request is sponsored by Donna Wheeler, Finance Team
Leader, Idaho Power Company, and Aubrae Sloan, Accounting Manager, ldaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 18
REQUEST FOR P cTtoN No. 2.13:Please list the types of facilities
(poles, wires, meters, etc.) that ldaho Power uses in its transmission (138 kV and 161
kV) system. For each facility type, please provide:
a. The total capital cost for all facilities of that type
b. The percentage of the capital cost to the total capital cost for the
transmission system
c. The portion of the capital cost for all facilities of that type that are
constructed pursuant to an interconnection agreement governed by and subject to the
Schedule 72 O&M fees
d. The percentage of the value produced in response to 2.13(c) to the total
for all facilities are constructed pursuant to an interconnection agreement governed by
and subject to the Schedule 72 O&M fees
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.13: ln response to
subparts a and b, the following table provides the total capital cost and associated
percentage of the Company's facilities classified as transmission as of December 31,
2017:
Account Account Description 1213112017 Balance Percentage
350
352
353
354
355
356
359
Land and Land Rights
Structures and I mprovements
Station Equipment
Towers and Fixtures
Poles and Fixtures
Overhead Cond uctors, Devices
Roads and Trails
Total Transmission Plant
$37,127,446.32
80,263,617.42
428,949,668.65
206,552,728.83
183,335,656.95
226,621,105.58
390,266.18
$ 1,153,240,489.93
3.19o/o
6.90%
36.88%
17.760/o
15.760/o
19.48Yo
0.03%
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 19
Please note that ldaho Power's transmission assets also include line assets that
are operated at less than 138 kV and at above 161 kV. The value of those transmission
assets is included within the table above.
Regarding subparts c and d, all capital costs associated with QF interconnection
facilities are to be reimbursed by the project when initially constructed, so those facilities
are recorded at net zero cost and thus not included in the response to subparts a and b.
Any remaining unreimbursed original facilities construction costs and any capital
expenditure to replace these facilities are deemed a part of ldaho Power's plant, the
same as any other plant that is not customer funded and is not uniquely identified or
tracked in the Company's accounting records.
The response to this Request is sponsored by Donna Wheeler, Finance Team
Leader, ldaho Power Company, and Aubrae Sloan, Accounting Manager, ldaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION .20
REQUEST FOR PRODUCTION NO. 2.14: What is the average age of all of
ldaho Power's distribution facilities?
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.14: The Com pany
periodically engages a depreciation consultant to study and review its plant records for
the purpose of preparing and proposing updated depreciation rates that reflect analysis
of historical plant activity, management's practice and outlook of plant operations, and
current practice in the electric industry. The Company's most recent deprecation study
was performed by Gannett Flemming using ldaho Power's available plant data as of
December 31,2015. The complete depreciation study, as prepared and proposed by
Gannett Flemming, is available at:
The depreciation study results provide a summary table that includes a
calculated annual Composite Remaining Life value based upon Future Accruals divided
by the Calculated Annual Accrual Amount for each plant account studied. The
Composite Remaining Life values that are reflective of the approved depreciation rates
provided for in the ldaho Public Utilities Commission's Order No. 33770 related to the
Company's distribution facilities, subject to the study, are included in the table below:
Account DISTR!BUTION PLANT
COMPOSITE
REMAINING
LIFE
361.00
362.00
364.00
365.00
366.00
367.00
STRUCTURES AN D IM PROVEMENTS
STATION EQUIPMENT
POLES, TOWERS AND FIXTURES
OVERHEAD CONDUCTORS AND DEVICES
UNDERGROUND CONDUIT
UNDERGROUND CONDUCTORS AND DEVICES
54.4
42.9
44.1
34.4
49.1
39.4
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 21
Account DISTRIBUTION PLANT
LINE TRANSFORMERS
SERVICES
METERS
METERS - AMI
INSTALLATION ON CUSTOMER PREMISES
STREET LIGHTING AND SIGNAL SYSTEMS
COMPOSITE
REMAINING
LIFE
368.00
369.00
370.00
370.1 0
371.20
373.20
34.8
43.4
25.7
14.0
14.7
29.0
The response to this Request is sponsored by Donna Wheeler, Finance Team
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 22
REQUEST FOR PRODUCTION NO. 2.15: What is the average age of the
distribution facilities constructed pursuant to an interconnection agreement governed by
and subject to the Schedule 72 O&M fees?
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.15: First energy dates,
which approximates the completion of construction, have been included in the
information provided in the Company's response to REC's Request for Production No.
2.6. The first energy date can be used to derive the average age of the distribution
facilities.
The response to this Request is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 23
REQUEST FOR PRODUCTION NO.2.16: What is the average age of all of
ldaho Power's transmission facilities?
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.16: The Company
periodically engages a depreciation consultant to study and review its plant records for
the purpose of preparing and proposing updated depreciation rates that reflect analysis
of historical plant activity, management's practice and outlook of plant operations, and
current practice in the electric industry. The Company's most recent deprecation study
was performed by Gannett Flemming using ldaho Power's available plant data as of
December 31,2015. The complete depreciation study, as prepared and proposed by
Gannett Flemming, is available at:
The depreciation study results provide a summary table that includes a
calculated annual Composite Remaining Life value based upon Future Accruals divided
by the Calculated Annual Accrual Amount for each plant account studied. The
Composite Remaining Life values that are reflective of the approved depreciation rates
provided for in the ldaho Public Utilities Commission's Order No. 33770 related to the
Company's transmission facilities, subject to the study, are included in the table below:
COMPOSITE
REMAINING
Account DISTRIBUTION PLANT LIFE
350.20
352.00
353.00
354.00
355.00
356.00
LAND RIGHTS AND EASEMENTS
STRUCTURES AND IMPROVEMENTS
STATION EQUIPMENT
TOWERS AND FIXTURES
POLES AND FIXTURES
OVERHEAD CONDUCTORS AND DEVICES
85.2
53.2
42.0
71.1
53.9
62.3
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 24
Account DISTRIBUTION PLANT
ROADS AND TRAILS
COMPOSITE
REMAINING
LIFE
359.00 33.3
The response to this Request is sponsored by Donna Wheeler, Finance Team
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 25
REQUJST FOR PRODUCTION NO. 2.17: What is the average age of the
transmission facilities constructed pursuant to an interconnection agreement governed
by and subject to the Schedule 72 O&M fees?
RESPONSE TO REQUEST FOR PRODUCTION NO. 2.17: First energy dates,
which approximates the completion of construction, have been included in the
information provided in the Company's response to REC's Request for Production No.
2.6. The first energy date can be used to derive the average age of the transmission
facilities.
The response to this Request is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
DATED at Boise, ldaho, this 31st day of July 2018.0.*ffu
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 26
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 31st day of July 2018 | served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE ENERGY
COALITION'S SECOND REQUEST FOR PRODUCTION upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Edith L. Pacillo
Edward Jewell
Deputy Attorneys General
ldaho Public Utilities Commission
47 2 W est Wash i ngton (83702)
P.O. Box 83720
Boise, ldaho 83720-0074
J. R. Simplot Company
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
ldahydro and Shorock Hydro, !nc.
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, Idaho 83701
Renewable Energy Coalition
J. Kahle Becker
Attorney at Law
223 North 6th Street, Suite 325
Boise, ldaho 83702
lrion Sanger
SANGER LAW, P.C.
1117 SW 53rd Avenue
Portland, Oregon 97215
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
edwa rd.jewel l@ p uc. id a h o. qov
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_Overnight Mail
_FAXX Email [e-mail]
q reo @ richardsonadams. com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXxEmail [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
FAX
X Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mai!
_FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 27
Tamarack Energy Partnership
Michael C. Creamer
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street (83702)
P.O. Box 2720
Boise, ldaho 83701
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
pnc@q ivenspu rslev. com
Avista Corporation
Michael G. Andrea, Senior Counsel
Avista Corporation
1411 East Mission Avenue, MSC-23
Spokane, Wash i ngto n 99202
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
Clint Kalich
Manager, Resource Planning and Analysis
Avista Corporation
1411 East Mission Avenue, MSC-7
Spokane, Washington 99202
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
Christa rry,sta
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
ENERGY COALITION'S SECOND REQUEST FOR PRODUCTION - 28