20150204Staff 1-27 to PAC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFTCORP DBA ROCKY MOUNTAIN ) CASE NOS. rPC-E-14-41
POWER AND rDAHO POWER COMPANY FOR ) PAC-E-14-11
AN ORDER AUTHORIZING THE EXCHANGE )
OF CERTAIN TRANSMISSION ASSETS. ) FIRST PRODUCTION REQUEST
) OF THE COMMISSION STAFF
) TO ROCKY MOUNTAIN POWER
)
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Daphne Huang, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power,
(Rocky Mountain) provide the following documents and information as soon as possible, but no
later than WEDNESDAY, FEBRUARY 25,2015.
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. IDAPA 31.01.01 .062,31.01.01.228.
This Production Request is to be considered as continuing, and Rocky Mountain 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 produced.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER FEBRUARY 4,2015
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 identiff the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD formulas activated.
REQUEST NO. l: What are the average monthly operation and maintenance expenses
currently associated with the plant in service that is proposed to be transferred to Idaho Power
from PacifiCorp?
REQUEST NO. 2: What are the average monthly operation and maintenance expenses
estimated to be associated with the plant in service that is proposed to be transferred to
PacifiCorp from Idaho Power?
REQUEST NO.3: Will there be any financial gain or loss associated with the transfer
ofassets? Ifso, please provide the specific details and associated assets.
REQUEST NO. 4: Please provide the proposed journal entries associated with the
transfer of assets.
REQUEST NO. 5: Please quantify the financial benefits to PacifiCorp customers for the
transparency, flexibility, and reliability accomplished by this transfer.
REQUEST NO. 6: What future anticipated projects, including capital, maintenance, and
operational, will no longer be needed as a result of this transfer of assets? Please list each project
that will not be undertaken or revised as a result of this asset transfer.
REQUEST NO. 7: Please provide a schedule showing the plant in service by specific
plant account, original cost, current book value, current depreciation expense and accumulated
depreciation for the assets to be transferred to Idaho Power.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER FEBRUARY 4,2015
REQUEST NO. 8: The Joint Purchase and Sale Agreement (JPSA) requires Idaho
Power to be responsible for the 230 kV Upgrades necessary to provide PacifiCorp with 51OMW
of long-term firm point-to-point transmission service on Idaho Power's transmission system.
(Application, JPSA, p9.27, Section 2.9(b)(xiv).) Please specify the specific equipment
purchased or upgraded, and the location of these required investments along with an explanation
of whether there will be any impacts to path ratings, the flexibility of transmission transfers, or
transmission capacity.
REQUEST NO. 9: Regarding the benefits discussed in Rick Vail's direct testimony,
please describe whether the asset exchange eliminates the need for additional transmission
investments in order to serve retail, wholesale, or generation customers. (Application, Vail DI,
pg.T,lines 15-17.)
REQUEST NO. 10: Please explain PacifiCorp's transmission scheduling process and
whether any manual scheduling processes will be replaced by automatic process(es) following
the execution of the Joint Ownership and Operations Agreement (JOOA). (Application, Grow
DI, pg. 12, lines 12-14.) If so, please provide a detailed description of the automatic scheduling
process(es), including the development and expected implementation date. Further, please
provide additional details regarding the capabilities of the automatic scheduling process for inter-
hour dispatch or dynamic transfers of energy.
REQUEST NO. 11: Lisa Grow's testimony says that the Parties are to create a method
to determine and allocate losses for the use of the transmission system within the other Party's
Balancing Authority Area. (Application, DI Grow, pg. 13, lines 8-12.) Please provide a
description of the previous method, the new method, and the associated implementation time
line.
REQUEST NO. 12: Please provide copies of the Phase 1, and if available the Phase II,
Environmental Site Assessments for the properties proposed to be transferred to Idaho Power
under the JPSA.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER FEBRUARY 4,2015
REQUEST NO. 13: Please provide a list of the FERC accounts used in the calculations
presented in Exhibit No. 8 (Application, DI Vail), along with a list of the FERC accounts used in
the current Energy Cost Adjustment Method (ECAM). Please explain how the transmission
expenses and revenues are expected to change as a result ofthe asset exchange, by FERC
account or other tracking method.
REQUEST NO. 14: Please provide supporting documentation for the load forecasts and
the projected date of the future service requirements, plus the current transmission use by retail,
wholesale, and generation customers served in the Jim Bridger Area, West of Kingport Area, and
North of Goshen Area. (Application, Vail DI, pg. 8-15.)
REQUEST NO. 15: Please provide supporting cost estimates associated with Rick
Vail's testimony regarding the lower upgrade costs to PacifiCorp customers. (Application, Vail
DI, pg. 12, lines 4-8.)
REQUEST NO. 16: Please provide an explanation of whether Bonneville Power
Administration, Avista, or Idaho Power transmission wheeling revenue for PacifiCorp will be
impacted (i.e., increased or reduced) following the proposed acquisition of assets.
REQUEST NO. 17: What are the estimated changes to the ldaho-Northwest path ratings
following the anticipated Walla Walla - Hurricane line upgrades? (Application, Angel DI, pg.
18, lines 12-14.)
REQUEST NO. 18: Please explain whether there are any areas within PacifiCorp's
Balancing Authority Area where an Energy Imbalance Market, or Security Constrained
Economic Dispatch, has not been implemented. Please also explain how the proposed
acquisition of assets may create new opportunities or improved functionality for load balancing
within shortened intervals (i.e., 5 minute). Please provide a general overview of additional
investments that may be required in the future in order to increase this type of dispatch
functionality.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER FEBRUARY 4,2015
RBQUEST NO. 19: Please explain whether the asset exchange
or decreases in retail customer rates.
cause any increases
REQUEST NO.20: The JPSA includes Planned Improvements (Application, JPSA) to
be completed by both Idaho Power (Schedule 1.1(e)) and PacifiCorp (Schedule l 1(f)). Please
explain whether there will be any impacts to path ratings, the flexibility of transmission transfers,
or transmission capacity as a result of the listed improvements.
REQUEST NO. 21: Please provide the current OATT formula Excel spreadsheet and
calculations, and the anticipated revised OATT formula Excel spreadsheet as a result of the
elimination of the various legacy agreements.
REQUEST NO.22: Please provide a copy of the responses submitted to the Western
Electricity Coordination Council (WECC) for the 2074 Operational Practices Survey Report
along with an explanation of whether any of the practices are anticipated to be revised during
2015, including as a result of the proposed asset exchange.
REQUEST NO. 23: Please explain how the Parties plan to coordinate compliance with
NERC- or State-required physical and cyber security program requirements given the proposed
asset exchange.
REQUEST NO. 24: Please explain how the Parties currently ensure the accuracy and
sharing of near term studies and whether the current methods will be revised following the
proposed asset exchange. If so, please further explain how the Parties will ensure the
interconnection-model and near-term-studies are accurate in the future.
REQUEST NO. 25: Please explain how the Parties plan to ensure the accuracy and
sharing of long-term operation studies, including shoulder periods, relay settings, remedial action
scheme impacts, and outage coordination following the proposed asset exchange.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER FEBRUARY 4,2015
REQUEST NO. 26: Please explain how the asset exchanges and upgrades to the Idaho -
Northwest Transmission (Hemmingway - Summer Lake 500 kV, Walla Walla - Hurricane23}
kV, and Midpoint - Hemmingway 500 kV) and associated substations revise the costs and
benefits of the proposed Boardman to Hemmingway transmission expansion.
REQUEST NO. 27: Please explain whether SCADA installations exist or are planned
for the Goshen Load Area to assist with load shedding or curtailment practices.
DATED at Boise, Idaho, this ry day of February 2014.
Technical Staff: Kathy Stockton/l-7
Johanna BelllS-Z7
Umisc/prod req/ipce I 4.4 l_pac-e- I 4- I I djhjbkls prodreq I rpm
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FIRST PRODUCTION
ROCKY MOUNTAIN
REQUEST TO
POWER 6
Deputy Attorney General
FEBRUARY 4,201,5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF FEBRUARY 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOtIrlrArN POWER, IN CASE NOS.
IPC-E-14.41 /PAC-E-I4.l1, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
JULIA A HILTON
IDAHO POWER CO
PO BOX 70
BOISE ID 83707
E-MAIL: [e-mail]
INDUSTRIAL CUSTOMERS OF IDAHO
POWER
C/O PETER J. RICHARDSON
RICHARDSON ADAMS PLLC
515 N. 27TH ST
BOISE, IDAHO 83702
E-MAIL: [e-mail]
DANIEL SOLANDER
TED WESTON
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84I 11
E-MAIL: [e-mail]
ted.weston@pacifi corp. com
DR. DON READING
6070 HILL ROAD
BOISE,IDAHO 83703
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE