20070713PAC to Staff 1-5.pdf

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201 South Main, Suite 2300
Salt lake City, Utah 84111
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July 12 2007
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Boise, ID 83702-5983
RE:ID PAC-07-
IPUC Staff Production 1 st Set Data Requests (1-
Please find enclosed Rocky Mountain Power s Response to IPUC Staff Production Data Request
1.5.
If you have any questions, please call Barry Bell at [phone].
Sincerely,
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Brian Dickman, Manager
Regulation
Enclosures
cc. Jean Jewell/IPUC
PAC-07-12/Rocky Mountain Power
July 12 2007
IPU C Staff Production 1 s1 Set Data Request 1.
IPUC Staff Production 1st Set Data Request 1.5
Please provide additional justification for transfer of RMP service territory and
150 customers to Fall River. How will this benefit RMP and its remaining
customers?
Response to IPUC Staff Production 1st Set Data Request 1.5
As stated in the joint application that was submitted to the Idaho Public Utilities
Commission for approval of the sale and transfer of property between Rocky
Mountain Power and Fall River Rural Electric Cooperative, Rocky Mountain
Power serves 150 customers in Teton County. The proposed transaction involves
the transfer of 72 of those customers from Rocky Mountain Power to Fall River.
As noted in the joint application, the primary reason for the parties to enter into
the proposed transaction is to eliminate the potential for duplication of facilities
that can result from service territories that are not clearly delineated or not
delineated in a manner that best suits the parties existing infrastructure and that
does not accommodate the addition of infrastructure to meet growth demands.
The parties to this proposed transaction were able to identify customer benefits
associated with modifying the service territory that are mutually beneficial to both
companies. These benefits include the following:
1) Eliminating the potential for duplication of facilities. For example, Rocky
Mountain Power presently has a single-phase distribution line that intersects an
area where Fall River presently has a three-phase distribution line. Compounding
this existing duplication is anticipated growth from a home development taking
place in this same area, which, without this transaction, will likely result in the
additional duplication of facilities.
2) Promoting the efficient use of existing facilities and the efficient use of
future facilities. As noted above, Rocky Mountain Power presently has a single-
phase distribution line that intersects Fall River s three-phase distribution line
and Fall River is in a better position, with respect to existing infrastructure and
other resources, to provide service to the existing and future customers in this
area. Also refer to the response to IPUC Production Request No. 1., wherein Fall
River provides information pertaining to manpower it has available to provide
service to customers in the area.
3) Minimizing and eliminating other operation issues. In addition to the
examples cited above, much of the load growth in the Teton County valley area is
already contracted to Fall River; therefore, Rocky Mountain Power expects to
experience little customer growth to offset the costs of line construction and
restoration efforts. Accordingly, the benefit to the remaining customers of Rocky
Mountain Power is the avoided cost of rebuilding the aging facilities that are
proposed to be transferred, primarily the principal distribution line. It is also
PAC-07-12/Rocky Mountain Power
July 12, 2007
IPUC Staff Production 1 s1 Set Data Request 1.
anticipated there will be a marginal reduction in operating expenses associated
with eliminating line restoration efforts. Furthermore, given the location of the
growth in the area and its relationship to the parties' existing certificated service
territories and the existing infrastructure and resources of the parties, it is more
economical for developers in the area to obtain service from Fall River.
(Rocky Mountain Power will sponsor this response at hearing. It has not been
determined specifically who at Rocky Mountain Power will sponsor the
response. )