20230306Staff 26-37 to IPC.pdf

RILEY NEWTON E \VED
MICHAEL DUVAL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 ,'3 iBOISE,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 )SECOND 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 27,2023.
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 informationproduced.
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 telephone number of
SECOND PRODUCTION REQUEST
TO IDAHO POWER 1 MARCH 6,2023
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 with formulas intact and enabled.
REQUESTNO.26:The Application for Case No.PAC-E-23-01,PacifiCorp ("PAC")
states there will need to be 10 communication stations built within the right of way of the
proposed transmission line.See Case No.PAC-E-23-01,Application at 5.Please confirm if
these communication stations are included in the Company's Boardman to Hemingway ("B2H")
project scope and cost estimate.If these are included in the project scope,please:
a.Provide a map indicating where the 10 communication stations will be located along
the transmission line;and
b.Provide the estimated cost to build each communication station.
REQUESTNO.27:In Case No.PAC-E-23-01,PAC witness Vail describes access
roads being constructed in the B2H project.See Case No.PAC-E-23-01,Vail Direct at 2.
However,the Company did not mention road construction in its Application.Please confirm if
access road costs are included in the Company's plan for building the transmission line.If these
are included in the project scope,please describe the following:
a.The scope of work for constructing new access roads including the number of miles
needed,the estimated costs,and timeline for construction;and
b.The scope of work for modification of existing access roads including the number
of miles that need modification,the estimated costs,and timeline for construction.
REQUESTNO.28:Company witness Ellsworth identifies many of the B2H project
cost assumptions made for the 2021 Integrated Resource Plan ("IRP")analysis.Ellsworth Direct
at 48-50.However,it is difficult to account for all the scope elements throughout his testimony.
Please provide the following:
a.Please provide a tabulated comparison of the project scope that was assumed in the
2021 IRP,and the scope currentlyincluded in the project [as defined by the Joint
Construction Funding Agreement ("JCFA")];
SECOND PRODUCTION REQUEST
TO IDAHO POWER 2 MARCH 6,2023
b.Please include the cost that was estimated for each scope element assumed in the IRP
and the current cost estimate for each element;and
c.Please provide a list of any B2H-related costs that are outside of the JCFA,such as
the Midpoint Transformer Upgrade.
REQUESTNO.29:The predicted cost of wholesale power is an important factor in the
IRP Aurora modeling.Please provide the following:
a.Please provide an hour-by-hourcomparison of the 2021 IRP modeled Mid-C market
prices with the actual Mid-C market prices for 2021 and 2022;and
b.Please identify causal factors and provide explanations for any significant differences
between the two,especially during critical summer months.
REQUESTNO.30:Please quantifythe followingbenefits that the Company expects to
gain from the proposed B2H project and provide supporting workpapers:
a.Please quantifythe expected benefits for native load customers;
b.Please quantifythe expected benefits from off-system sales;
c.Please quantifythe expected benefits from wheeling power as a result of B2H;
d.Please list and describe in detail any other benefits that cannot be readily quantified;
and
e.Please quantifythe expected benefits by year over the IRP planning cycle.
REQUESTNO.31:In Company witness Barrett's testimony,she stated "milestone
dates will be tied to monetary penalties for the construction manager if key dates slip."Barrett
Direct at 40.Please describe the milestone dates to which the construction manager will have to
adhere.Please provide a workpaper that includes penalties associated with each milestone.
REQUESTNO.32:Please provide the forecasted operation and maintenance costs for
the proposed B2H transmission line.Please provide supporting workpapers that detail costs by
year over the IRP planning period.
SECOND PRODUCTIONREQUEST
TO IDAHO POWER 3 MARCH 6,2023
REQUESTNO.33:Production Request No.7 asks why Bonneville Power Association
("BPA")wants out of the deal.Please explain why the Company decided to buyout all of BPA's
interest as opposed to PAC buying out the interest,or the Company and PAC splitting the
buyout.
REQUESTNO.34:Please describe the forecasted timeline for the reimbursement of
BPA's permitting costs.Ellsworth Direct at 14.Please provide supporting workpapers that
show terms and repayment by year.
REQUESTNO.35:Company witness Ellsworth testifies that the extra 24%of B2H
transmission capacity the Company will acquire from BPA "will primarily be used to provide
BPA network transmission service under Idaho Power's Open Access Transmission Tariff
('OATT')."Ellsworth Direct at 11.
a.Please provide the forecasted annual OATT revenue that the Company expects to
receive from BPA for this service,includingthe underlyingwheeling volume and
tariff rates;
b.Please provide any data supplied by BPA concerning its forecasted wheeling
requirements across B2H;and
c.Please provide the Company's analysis for recovering its additional 24%capital cost
and the additional 24%operation and maintenance cost.
REQUESTNO.36:Company witness Ellsworth testifies that there are several other
transactions that are necessary for B2H,but not directlyrelated to construction and operation of
the B2H project.Ellsworth Direct at 19.For the four proposed asset exchanges,please provide
the following:
a.Please explain why each one of these is necessary for B2H;and
b.Please explain the Company's contingency plans if any of the asset exchanges are
prevented or not implemented.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 4 MARCH 6,2023
REQUESTNO.37:In Case No.PAC-E-23-01,PAC witness Link described the United
States Environmental Protection Agency's proposed Ozone Transport Rule ("Rule")that would
restrict Nitrous Oxide ("NOx")emissions from power plants and other industrial sources.See
Case No.PAC-E-23-01,Link Direct at 15.Please answer the following:
a.Please explain the Company's assessment of the Rule and likely impacts to the
Company;and
b.Please explain if the Company incorporated any of the economic implications from
this rule into its analysis of the project,and if so,please explain how.
DATED at Boise,Idaho,this day of March 2023.
Michael Duval
Deputy AttorneyGeneral
i:umise:prodreq/ipce23.lrnms prod req 2
SECOND PRODUCTION REQUEST
TO IDAHO POWER 5 MARCH 6,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF MARCH 2023,SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-23-01,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER TIMOTHY TATUM
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
EMMA E.SPERRY
IDAHO CONSERVATION LEAGUE
710 N.6TH STREET
BOISE,ID 83702
E-MAIL:[e-mail]
SECRETAR
CERTIFICATE OF SERVICE