20230213Staff 1-25 to IPC.pdf

RILEY NEWTON
MICHAEL DUVAL
DEPUTY ATTORNEYS GENERAL i e n
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]/334-0320
IDAHO BAR NOS.11202 &11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR A )CASE NO.IPC-E-23-01CERTIFICATEOFPUBLICCONVENIENCE)AND NECESSITY FOR THE BOARDMAN TO )HEMINGWAY 5OO-KV TRANSMISSION )FIRST PRODUCTIONLINE)REQUESTOF THE
)COMMISSION STAFF
)TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy Attorney General,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than MONDAY,MARCH 6,2023.
This Production Request is to be considered as continuing,and the Company 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 or information produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title,and telephonenumber of
FIRST PRODUCTIONREQUEST
TO IDAHO POWER 1 FEBRUARY 13,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUESTNO.1:Please provide supporting documents and workpapers with formulas
intact for all Company testimony and exhibits.
REQUESTNO.2:Please provide detailed and legible project maps portraying the
operational components (substations,lines,etc.)and proposed transfer components,as described
in agreements between the Company and its partners.Indicate name,physical location,
agreement reference(s),and ownership.
REQUESTNO.3:The Company's Exhibit 11 provides a high-leveloverview of the
Boardman to Hemingway ("B2H")cost estimate.Please provide the underlyingworksheets
showing the major expense components for the followingline items in the exhibit:
a.Transmission Line Construction and MitigationDirect Costs,
b.Pre-Construction Costs,
c.Right of Way Option Costs,
d.Substation Total,
e.Local Interconnection Costs,and
f.Idaho Power AFUDC &Property Tax.
REQUESTNO.4:Company Witness Barretto testifies that "[t]he B2H project will
require...removalof 12 miles of existing 69-kV transmission line,rebuilding 0.9 miles of a 230-
kV transmission line,and rebuilding of 1.1 miles of an existing 138-kV transmission line into a
new right-of-way."Barretto Direct at 3.Please provide the following:
a.A detailed explanation of the need,
b.The location,
c.The scope of work,and
d.The estimated cost.
FIRST PRODUCTIONREQUEST
TO IDAHO POWER 2 FEBRUARY 13,2023
REQUESTNO.5:Company Witness Ellsworth discusses both the "Midline Series
Capacitor substation"associated with the B2H Project Joint Construction Funding Agreement,
and the "Kinport -Midpoint 345-kV Series Capacitor Bank Project"associated with the Kinport
Capacitor Bank Construction Agreement.Ellsworth Direct at 23-24.To help Staff distinguish
between these two projects,please provide the followingfor each project:
a.The project purpose,
b.The project location,
c.The project scope of work,and
d.The estimated project cost.
REQUESTNO.6:The Company's Application describes a complex plan with many
significant projects and transactions that are distinct from constructing the B2H transmission
line.Staff offers the followinglist of projects and transactions it has noted in the Application:
a.BuyoutBonneville Power Association's ("BPA")Permit Interest.
1.Establish the Joint Permit Funding Agreement.
2.Establish the Purchase,Sale,and Security Agreement.
3.Establish the Network Integration Transmission Service Agreement
("NITSA")for Goshen load.
4.Establish the NITSA for Idaho Falls load.
5.Establish a point-to-point("PTP")Transmission Service Agreement ("TSA")
from the Mid-Columbia ("Mid-C")hub to the proposed Longhorn substation.
6.BPA will redirect two 100 MW PTP TSAs from the Company to PacifiCorp.
7.Establish the Longhorn Substation Funding Agreement.
b.Construct the B2H Core Project.
1.Establish the Joint Construction Funding Agreement with PacifiCorp.
2.Construct the main transmission line.
3.Rebuild or remove certain other transmission segments.
4.Construct the Longhorn substation.
5.Upgradethe Hemingway substation.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 FEBRUARY 13,2023
6.Construct the Midline Series Capacitor substation.
c.Asset Swaps and Construction Agreements with PacifiCorp.
1.Company transfer to PacifiCorp transmission assets between Midpoint and
Borah for 300 MW west-to-east capacity.
2.Company transfer to PacifiCorp transmission assets between Borah and
Hemingway for 600 MW east-to-west capacity.
3.PacifiCorp transfer to the Company transmission assets between Populus and
Four Corners for 200 MW of bi-directional capacity.
4.PacifiCorp transfer to the Company identified Goshen area assets.
5.Establish a construction agreement and construct the Midpoint 500/345-kV
Transformer Project.
6.Establish a construction agreement and construct the Kinport-Midpoint345-
kV Series Capacitor Bank Project.
For each of these projects or transactions above (and any others inadvertently omitted by Staff),
please provide the following:
a.Please identify which of these projects/transactions that the Company is seeking
Commission authorization under the Certificate of Public Convenience and Necessity
("CPCN").
b.Please identify which of these projects/transactions that the Company is seeking
Commission authorization in this case but not specifically under the CPCN.
c.Please identify which of these projects/transaction that the Company plans to seek
Commission authorization outside of this case.If seeking authorization outside of
this case,when and how will the Company be seeking authorization?
d.For any projects/transactions that will be authorized outside of this case,please
discuss possible dependencies between them and the included projects/transactions.
REQUESTNO.7:Company Witness Ellsworth testifies that "...the Parties'capacity
needs,strategies,and goals associated with the B2H project have evolved...BPA will transition
out of its role as a joint permit funding coparticipant..."EllsworthDirect at 10.Please explain
why BPA wants out of its role.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 4 FEBRUARY 13,2023
REQUESTNO.8:Please provide the Company's 20-year Load &Resource Balance
("L&RB")showing the year and deficits justifying the need for B2H.Also,please provide the
following:
a.A list of any new resource projects (includingtheir rated capacity)supplying the
Company that have,or will,come online between the time the L&RB was established
and before B2H is energized.
b.If any of these projects are reflected in the L&RB,please correlate them.
REQUESTNO.9:Please explain how the Company will serve native load customers if
B2H is not approved?
REQUESTNO.10:Please explain how the Company will serve native load customers
if B2H is approved but completion is delayed beyond the 2026 deficiency date?
REQUESTNO.11:Please explain all potential fundingsources the Company has
considered and pursued to finance building B2H by answering the following:
a.Has the Company pursued available Federal funds for grid resilience and
transmission?If not,why not?If yes,please describe the funds available,status of
funding pursued,and how these funds potentiallyreduce impact to ratepayers?
b.Has the Company pursued available State funds throughthe Office of Energy and
Mineral Resources ("OEMR")?If not,why not?If yes,please describe the funds
available,status of funding pursued,and how these funds potentiallyreduce impact to
ratepayers?
c.Has the Company pursued funds throughthe Federal Emergency Management
Agency ("FEMA")and the Office of Emergency Management("OEM")?If not,why
not?If yes,please describe the funds available,status of funding pursued,and how
these funds potentiallyreduce impact to ratepayers?
d.Has the Company applied for any grants or other funding for the project?If so,what
were the sources,amounts,and application dates?
e.Has the Company been awarded any grants or other fundingfor the project?If so,
what were the sources,amounts,and dates awarded?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 5 FEBRUARY 13,2023
REQUESTNO.12:For BPA's construction of the Longhorn substation,please explain
when environmental compliance laws are expected to be met?Ellsworth Direct at 50.
REQUESTNO.13:Please describe the Company's contingency plans if BPA decides
not to pursue construction of the Longhorn substation.B2H Term Sheet Item No.7 at 26.
REQUESTNO.14:In Company Witness Ellsworth's testimony he states:"the loss of
the Hemingway-SummerLake 500-kV transmission line,the only 500-kV connection between
the Pacific Northwest and Idaho Power,during peak summer load,is one of the worst possible
contingencies the Company's transmission system can experience."EllsworthDirect at 61.
a.Please describe the occurrences,over the last ten years,where the Hemingway-
Summer Lake 500-kV transmission line was lost.Include the duration,cause,and
impact for each occurrence.
b.Please describe actions taken by the Company during the loss of the transmission line
by occurrence to serve load.
REQUESTNO.15:Please describe all lawsuits in process for the B2H project.In the
response,please include the following:
a.Case No.,
b.County filed in,
c.Name of parties,
d.Case caption,
e.Date filed,and
f.Any other relevant information.
REQUESTNO.16:Please describe all lawsuits resolved for the B2H project.In the
response,please include the following:
a.Case No.,
b.County filed in,
c.Name of parties,
FIRST PRODUCTIONREQUEST
TO IDAHO POWER 6 FEBRUARY 13,2023
d.Case caption,
e.Date filed,
f.Date resolved,
g.The outcome of the case,and
f.Any other relevant information.
REQUESTNO.17:Please describe all known pending lawsuits for the B2H project and
include all known informationabout the pending litigation.
REQUESTNO.18:Company Witness Ellsworth testifies that the Company assessed
five different data points regarding Mid-C market sufficiency.Ellsworth Direct at 78.To aid
Staff's review of market sufficiency,please provide the following:
a.The workpapers showing the Pacific Northwest forecast for 2030 winter and summer
peaks.Ellsworth Direct at 79.
b.The resource adequacy assessment performed by BPA.Ellsworth Direct at 79.
c.The workpapers evaluating the 6,389 MW of planned new resources through 2031.
Ellsworth Direct at 80.
d.Please list the current firm power commitments the Company has with Mid-C market
sellers during the summer peak.
e.Please address the prospect of obtaining future Mid-C firm power commitments for
summer peaks in light of the new California,Oregon,and Washington policies of
electrification.
REQUESTNO.19:Please evaluate the likelihood that pending permits will be issued
in time to complete construction by the end of 2026.If the delay risk is high for a permit,
describe the potential impact and the Company's plans to mitigate delays.
REQUESTNO.20:Please provide Company guidelines for affected landowner
compensation related to the B2H project.If the Company does not have guidelines,please
explain why not.
FIRST PRODUCTIONREQUEST
TO IDAHO POWER 7 FEBRUARY 13,2023
REQUESTNO.21:Please provide the followingto explain the Company's real estate
acquisitions in relation to the B2H route:
a.How many real estate parcels ("segments")must the Company acquire access and
construction rights to construct B2H?
b.To date,how many segments has the Company acquired,and how many remain to be
acquired?
c.To date,how much has the Company spent to compensate landowners?How much
more does the Company expect to spend?
REQUESTNO.22:Please provide the supporting workpapers for the Company's
analysis used to "calibrate"the project cost estimates against similar 500 kV projects described
in Company Witness Ellsworth testimony.Ellsworth Direct at 51.
REQUESTNO.23:Please describe the Requests For Proposals ("RFP")that are
currentlyopen for the B2H project.Please include the following:
a.A description of the product or service,
b.The required date,
c.The cost,
d.The vendor selection criteria,and
e.Supporting documents and workpapers.
REQUESTNO.24:Please describe the RFPs that are plannedfor the B2H project.
Please include the following:
a.A description of the product or service,
b.The required date,
c.The cost,
d.The vendor selection criteria,and
e.Supporting documents and workpapers.
FIRST PRODUCTIONREQUEST
TO IDAHO POWER 8 FEBRUARY 13,2023
REQUESTNO.25:Please provide the scope of work for the Hemingway substation to
integrate with the new B2H transmission line.Also,please provide worksheets with formulas
intact detailing the costs.
DATED at Boise,Idaho,this day of February 2023.
Michael Duval
Deputy Attorney General
i:umise:prodreq/ipce23.lrnms prod req l
FIRST PRODUCTIONREQUEST
TO IDAHO POWER 9 FEBRUARY 13,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF FEBRUARY 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-23-01,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER TIMOTHY TATUMIDAHOPOWERCOMPANYIDAHOPOWERCOMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
EMMA E.SPERRY
IDAHO CONSERVATIONLEAGUE
710 N.6TH STREET
BOISE,ID 83702
E-MAIL:esperry idahoconservation.org
SECRE Y
CERTIFICATE OF SERVICE