20080827Staff to PAC 1-21.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6864
RECEIVED
2088 AUG 21 AM 9= 02
IDAHO PUBLIC
UTiLITIES COMMiSSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR A )
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY AUTHORIZING )
CONSTRUCTION OF THE POPULUS-TO- )
TERMINAL 345 KV TRANSMISSION LINE )PROJECT )
)
)
CASE NO. P AC-E-08-3
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Rocky Mountain Power (Company; Rocky
Mountain) provide the following documents and information as soon as possible, but no later
than WEDNESDAY, SEPTEMBER 10,2008.
The Company 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. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Rocky Mountain is
requested to provide, by way of supplementar responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 1 AUGUST 27, 2008
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
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: The Company indicated in Utah DPU Request 1.31 that an update
for the project costs is due on the last week of August. Please provide the most recent update (if
available) for the Company's estimated cost of the project.
REQUEST NO.2: What is the current $/mile cost for building a new 345kV
transmission line?
REQUEST NO.3: What is the total length, in miles, of the new transmission line that
needs to be built? What is the total length in Idaho? What is the total length in Utah?
REQUEST NO.4: On a better resolution map, please identify all alternative
transmission routes considered and highlight the final route selected.
REQUEST NO.5: For each alternative route including the final route selected, please
provide all costs associated to build the transmission line on that paricular route.
REQUEST NO.6: In regards to the new Populus Substation that needs to be built,
please provide in detail:
a. Why is it necessar to build this substation instead of utilzing or upgrading
nearby substations for this project?
b. What other locations did the Company consider to build this substation and why
were they not chosen?
c. Why did the Company choose to build the substation at this location?
REQUEST NO.7: Please provide any relevant analysis available that shows:
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 2 AUGUST 27,2008
a. The curent transfer capacities on Path C without this project and explain how
it is used to serve the load in Idaho.
b. The new transfer capacities on Path C with this project and explain how it will
help serve the increased load and demand in Idaho.
REQUEST NO.8: Please explain how this project improves the service and reliabilty
in the Company's Idaho service territory.
REQUEST NO.9: Identify the location of outages caused by transmission failure in
Path C.
a. How wil this project prevent or mitigate similar outages and how will it
improve recovery from that condition in those areas affected by this project as
indicated in line 5 page 2 of Mr. Cupparo's testimony(provide supporting
metrics and any relevant analysis as needed)?
REQUEST NO. 10: Please provide comparison demonstrating why it is necessary to
pursue this project rather than upgrading the existing transmission corridors to increase transfer
capacity to handle the load growth?
REQUEST NO. 11: During the construction of the project, the 230kV transmission line
between Terminal and Ben Lomond wil be upgraded to 345kV. If this par of the line is under
constrction, what complications will this cause in the Company's service territory and other
adjacent areas? If so, please list the areas affected and any outages that will occur.
REQUEST NO. 12: Provide analysis demonstrating that this project does not diminish
curent reliability and how does this project improve reliability of the system as a whole in the
Idaho area. Please include any simulations, model, studies, etc. the Company conducted.
REQUEST NO. 13: Please explain and provide supporting information explaining why
this transmission line is necessary to relieve constraints in the system according to the Western
Governor's Association.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 3 AUGUST 27,2008
a. How does this transmission line help with congestion in the system (provide
analysis, documents, etc. as needed)?
REQUEST NO. 14: What kind of equipment/new technologies is the Company utilizing
for this project to improve power transfer effciency?
REQUEST NO. 15: How wil this project utilize energy from Goshen Wind Far?
How much of the maximum transfer capacity of the new transmission line is allocated to
renewable resources?
REQUEST NO. 16: Please provide any agreements with local wind fars or any other
renewable energy provider who wil utilize this line.
REQUEST NO. 17: Per commitment #34 from the acquisition case (PAC-E-05-08),
what are the future considerations of planed generating capacity other than the energy from
renewable resources? Please provide details of planed additions and how these additions wil
help serve the increased load and demand in Idaho.
REQUEST NO. 18: Has the Company obtain all the required land use permits from
county or local governent in the State of Idaho for this project? Please explain.
REQUEST NO. 19: In paragraph 9 of the Company's application, the Company stated
that the impact of the project on Idaho's rate is estimated to be 3%. Although there will be no
determination ofprudency, cost recovery or cost allocation in this case, please give detals on
how the 3% amount was calculated.
REQUEST NO. 20: Please provide analysis demonstrating how this project relieves
congestion in the system.
REQUEST NO. 21: Please provide supporting information explaining the immediate
reliability impact and meet the increased load and demand.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 4 AUGUST 27,2008
DATED at Boise, Idaho, this ~y of August 2008.
IL~
~eil Price
Deputy Attorney General
Technical Staff: TJ Golo
i:umisc:prodreq/pace08.3nptj prod req 1
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 5 AUGUST 27,2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF AUGUST 2008,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-08-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA SYONDS
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE
SALT LAKE CITY UT 84116
E-MAIL: lisa.symonds(fpacificorp.com
R JEFF RICHARDS
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: jeff.richards(fpacificorp.com
DATA REQUEST RESPONSE CENTER
PACIFICORP
825 NE MUL TNOMAH STE 2000
PORTLAND OR 97232
E-MAIL: dataequestcmpacificorp.com
~f~-SECRETAR
CERTIFICATE OF SERVICE