20150206PAC to ICIP 1-8.pdf

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An IDACORP Company', :' ,
?CI5 t[i] -ri l'li h' 5l
JULIA A. HILTON
Corporate Counsel
ih i [e-mail]
February6,2015
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case Nos. IPC-E-14-41 and PAC-E-14-11
Exchange of Certain Transmission Assets - PacifiCorp's Response to the
First Production Request of the lndustrial Customers of ldaho Power
Dear Ms. Jewell:
Enclosed for filing in the above matters please find duplicate originals and three
(3) copies of PacifiCorp's Response to the First Production Request of the lndustrial
Customers of ldaho Power.
AIso enclosed are five (5) copies each of non-confidential and confidential disks
containing information responsive to the Industrial Customers of ldaho Power's requests
for production.
lf you have any questions about this filing, please contact Ted Weston, PacifiCorp
Manager of Regulation, at (801 ) 220-2963 or me at (208) 388-611 7.
JAH:kkt
Enclosures
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
Very truly yours,
Julia A. Hilton
JULIA A. HILTON (lSB No. 7740)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
ihilton@idahopower. com
Attorney for ldaho Power Company
DANIEL E. SOLANDER (lSB No. 8931)
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
Facsimile: (801 ) 220-3299
daniel. solander@pacificoro. com
Attorney for PacifiCorp
!N THE MATTER OF THE APPLICATION
OF PACIFICORP DBA ROCKY
MOUNTAIN POWER AND IDAHO POWER
COMPANY FOR AN ORDER
AUTHORIZING THE EXCHANGE OF
CERTAI N TRANSM ISSION ASSETS
Z0l5 FIB -5 P]i L: S t
CASE NOS. IPC-E-1441
PAC-E-14-11
PACIFICORP'S RESPONSE TO
THE FIRST PRODUCTION
REQUEST OF THE !NDUSTRIAL
CUSTOMERS OF IDAHO POWER
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW, PacifiCorp dlbla Rocky Mountain Power and Pacific Power
(collectively referred to as "PacifiCorp" or "Company"), and in response to the First
Production Request of the lndustrial Customers of ldaho Power to PacifiCorp dated
January 16,2015, herewith submits the following information:
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION NO. 1: Please provide copies of all material
provided to the Commission Staff regarding the Company's application that were
provided other than through formal discovery, both prior to, and after, the filing of the
Application.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Please refer to
Attachment 1 "ldaho Commission Presentation IPC-PAC Asset Exchange (Final)" which
contains a November 21, 2014, presentation to ldaho Public Utilities Commission staff
provided on the non-confidential CD.
The record holder for the response to this Request is Brian Fritz, PacifiCorp, and
is sponsored by Richard Vail, Vice President of Transmission, PacifiCorp.
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 2: Reference the direct testimony of
Gregory Duvall at page 11, stating:
Under the current RTSA, MTFA and other agreements,
PacifiCorp has east-to-west rights across the ldaho Power
transmission system of up to 1,600 MW and other various
rights at a projected 2016 cost of $20.8 million per year
escalating each year thereafter. This is made up of firm and
conditional firm service. Under the JPSA, PacifiCorp will
have rights under ldaho Power's OATT to use 510 MW of
firm point-to-point east-towest service across the ldaho
Power transmission system with an initial cost of $17 .1
million per year escalating each year thereafter in addition to
1090 MW of ownership.
a) Please provide the escalating rate for each year under the Legacy
Agreements and the proposed escalation rate for each year under the JPSA.
b) Please explain how the escalation rates for the proposed JPSA are
derived, and whether they are subject to change in the future. Also identify the
section of the JPSA attached to the Application supporting the answer.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
a) Legacy Agreements:
PacifiCorp payments to ldaho Power Company ("ldaho Power") under the
Restated Transmission Service Agreement ('RTSA') and Restated and Amended
Transmission Facilities Agreement ("p7qp14", are held constant at $7.65 million
annually with no escalation. However, in addition to payments under the Legacy
Agreements, PacifiCorp currently purchases 450 megawatts ("MW") of transmission
services from ldaho Power at tariff rates, which are subject to change. Additionally,
PacifiCorp purchases $1.1 million of short-term and non-firm transmission services from
Idaho Power at tariff rates, which are subject to change. Please refer to the attachment
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
provided in ldaho Power's response to the lndustrial Customers of ldaho Power's
("lClP') Request No. 7, subpart (a), which provides the year-to-year projection of Idaho
Power's Federal Energy Regulatory Commission ("FERC") Formula transmission tariff
rates.
Joint Purchase and Sale Agreement ("JPSA"):
PacifiCorp would purchase up to 510 MW of transmission services from ldaho
Power at tariff rates. Additionally, PacifiCorp would continue to purchase short-term
and non-firm transmission capacity from ldaho Power at tariff rates. Please refer to the
attachment provided in ldaho Power's response to lClP's Request No. 7, subpart (a),
which provides the year-to-year projection of ldaho Power's FERC Formula
transmission tariff rates.
b) The JPSA does not include any explicit provision for escalation. Please
refer to section 4.9 of the JPSA:
Firm Transmission Service Agreements. Prior to the
Closing, PacifiCorp shall submit to ldaho Power requests for
the Firm Transmission Service Agreements, pursuant to
ldaho Power's OATT.
The projections of ldaho Power's FERC formula transmission tariff rates were
provided by ldaho Power. ldaho Power will invoice PacifiCorp for transmission services
based on the rate in effect at the time of service. Future rates may vary from this
projection. Please refer to ldaho Power's response to lClP's Request No. 7, subpart
(a), which provides the projected ldaho Power FERC formula transmission tariff rates.
The record holder for the response to this Request is Mark Paul, PacifiCorp, and
is sponsored by Greg Duvall, Director of Net Power Costs, PacifiCorp..
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
REQUEST FOR PRODUCTION NO. 3: Reference Exhibit No. 8, p. 1, attached
to the direct testimony of PacifiCorp witness Richard Vail. Please provide:
a) A functioning electronic copy of Exhibit No. 8, p. 1 with formulas intact;
b) The work papers used to derive the values in Exhibit No. I p. 1;
c) The assumptions used in the 1O-year projections for the values in the
table;
d) For the purposes of Exhibit No. 8 does PacifiCorp assume it will not file a
general rate cases in ldaho that would impact the value such as the authorized rate of
return, revenues, expenses, etc. over the 10 year period?
RESPONSE TO REQUEST FOR PRODUGTION NO. 3:
Please refer to the following non-confidential and confidential attachments,
specifically:
a) Spreadsheet entitled "Exhibit 8, Page 1" (Attachment 1);
b) Spreadsheets entitled "ldaho Power - Proposed Exchange" (Confidential
Attachment 2) and "ldaho Power - Status Quo" (Confidential Attachment 3);
c) Document entitled "lPC Exchange Assumptions" (Confidential Attachment
4).
d) Although Exhibit No. 8 calculates the present value of revenue
requirements (PVRR) to PacifiCorp's retail customers based on the Company's current
financial assumptions including authorized rate of return, income tax rate, depreciation
rates, etc. this is not meant to imply that PacifiCorp will not file general rate cases over
the ten year period. Confidential information is provided subject to the terms and
conditions of the Protective Agreement in this proceeding. Please see the non-
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
confidential and confidential CDs for the attachments to this response. The confidential
CD wil! only be provided to those parties that have executed the Protective Agreement
in this matter.
The record holder for the response to this Request is Mark Pau!, PacifiCorp, and
is sponsored by Richard Vail, Vice President of Transmission, PacifiCorp.
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
REQUEST FOR PRODUCTION NO. 4: Reference Exhibit No. 8, p. 2, attached
to the direct testimony of Richard Vail. Please provide:
a) A functioning electronic copy of Exhibit No. 8, p. 2 with formulas intact;
b) The work papers used to derive the values in the table;
c) The assumptions used in deriving the values in Exhibit No. 8, p. 2.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please refer to the
fol lowing non-confidential and confidential aftachments, specifically:
a) Spreadsheet "Exhibit 8, Page 2" (Attachment 1);
b) Spreadsheets "9b" (Confidentia! Attachment 2) and "13" (Confidential
Attachment 3);
c) Refer to subpart (a) above.
Confidential information is provided subject to the terms and conditions of the
Protective Agreement in this proceeding. Please see the non-confidential and
confidentia! CDs for the attachments to this response. The confidential CD will only be
provided to those parties that have executed the Protective Agreement in this matter.
The record holder for the response to this Request is Brian Frilz, PacifiCorp, and
is sponsored by Richard Vail, Vice President of Transmission, PacifiCorp.
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 5: Exhibit No. 9 attached to the direct
testimony of PacifiCorp witness Richard Vail displays a set of values indicating the net
exchanges between PacifiCorp and ldaho Power Company, please provide:
a) A functioning electronic copy of Exhibit No. 9 with formulas intact;
b) The work papers used to derive the values in Exhibit No. 9;
c) The assumptions used in deriving the values in Exhibit No. 9;
d) The labels for values in Exhibit No. 9 (i.e., are they in thousands of
dollars?);
e) An explanation of'No Additions" and "Additions."
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: For subparts a-c,
please refer to the following non-confidential attachments provided on the non-
confidential CD, specifically:
a) Workbook "Exhibit 9" (Attachment 1);
b) Workbook "Summary Asset Swap Data" (Attachment 2) with supporting
files "PACAsset Exchange to IPC YR End 2014 - Fina!," (Attachment 3) and'IPC-PAC
Asset Swap Summary4PAC FINAL" (Attachment 4);
c) Refer to subpart (a) above.
d) The labels for values in Exhibit No. 9 are represented in thousands of
dollars.
e) "No Additions" is defined as assets currently in service. "Additions" are
defined as assets that will be placed in service on the effective date of the agreement.
The record holder for the response to this Request is Brian Fritz, PacifiCorp, and
is sponsored by Greg Duvall, Director of Net Power Costs, PacifiCorp.
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
REQUEST FOR PRODUCTION NO. 6: Reference the direct testimony of
Richard Vail, p. 12, stating "under the new joint ownership arrangements, costs for
future upgrades would be shared in accordance with the JOOA, potentially resulting in
lower upgrade costs to PacifiCorp's customers." Please provide all plans or studies,
including any cost estimates, regarding upgrades that will be necessary in the next ten
years on the lines referenced in this portion of Mr. Vail's testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Please refer to the
confidential attachment provided on the confidential CD. Confidentia! information is
provided subject to the terms and conditions of the Protective Agreement in this
proceeding. The confidential CD will only be provided to those parties that have
executed the Protective Agreement in this matter.
The record holder for the response to this Request is Brian Fritz, PacifiCorp, and
is sponsored by Richard Vai!, Vice President of Transmission, PacifiCorp..
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
REQUEST FOR PRODUCTION NO. 7: Reference the direct testimony of
Richard Vail, p. 14, lines 11-15, stating that the value of the assets being exchanged is
nearly equal and the ongoing expenses "will be similar to expenses incurred today."
Provide all studies, analyses and reports estimating the ongoing expenses for the next
ten years as compared to ongoing expenses with the Legacy Agreements.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: Under the terms of the
Joint Ownership and Operating Agreement each company wil! continue to perform
maintenance on the assets it currently maintains and the other owner will be required to
fund its share of the maintenance costs. Please refer to the attachments provided in
response to lClP's Request No. 3.
The record holder for the response to this Request is Brian Fritz, PacifiCorp, and
is sponsored by Richard Vail, Vice President of Transmission, PacifiCorp.
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1O
REQUEST FOR PRODUCTION NO. 8: Please provide all internal reports or
memoranda presenting the terms and/or benefits of the transaction to (a) PacifiCorp's
board of directors and (b) PacifiCorp's senior officers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The Company objects
to this request to the extent it requests information protected by attorney-client privilege.
Notwithstanding, and without waiving this objection, the Company responds as follows:
Please refer to Confidential Attachments 1 through 5 provided on the confidential CD
and Attachment 6 provided on the non-confidential CD. Portions of the memoranda
have been redacted for privilege. Confidential information is provided subject to the
terms and conditions of the protective agreement in this proceeding. The confidential
CD will only be provided to those parties that have executed the Protective Agreement
in this matter.
The record holder for the response to this Request is Patrick Cannon, PacifiCorp,
and is sponsored by Richard Vail, Vice President of Transmission, PacifiCorp.
DATED this 6th day of February 2015.
DANIEL E. SOLANDER
Attorney for Rocky Mountain Power
PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 11
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this 6th day of February 2015 I served a true and
correct copy of PACIFICORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
PacifiCorp
Daniel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
lndustria! Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
The United States Department of Energy and
the Federal Executive Agencies
Steven Porter, Assistant General Counsel
Electricity and Fossil Energy
Office of the General Counsel (GC-76)
United States Department of Energy
1000 lndependence Avenue, SW (Room 6D-033)
Washington, D.C.20585
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PACIFICORP'S RESPONSE TO THE FIRST PRODUCT]ON REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 12
Dwight Etheridge
10480 Little Patuxent Parlauay, Suite 300
Columbia, Maryland 21044
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PACIFIGORP'S RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 13