20150318Staff 34-40 to IPC.pdf

DAPHNE HUANG . : "' :.i
DEPUTY ATTORNEY GENERAL
IDAHo puBLIC uTILITIES coMMISSIoN 7015 ${ti[l lB f1}{ 9: 3tr
PO BOX 93720 :.. ,
BOISE, IDAHO g3720-0074 ij iil.liii''i1{-j,",;,i',,',1,,;,;;.,;
(208) 334-03 I 8
IDAHO BAR NO. 8370
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACTFTCORP DBA ROCKY MOUNTAIN ) CASE NOS. rPC-E-r4-41
POWER AND rDAHO POWER COMPANY FOR ) PAC-E-14-11
AN ORDER AUTHORIZING THE EXCHANGE )
OF CERTAIN TRANSMISSION ASSETS. ) SECOND PRODUCTION
) REQUEST OF THE COMMISSION
) STAFF TO rDAHO POWER
) COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, requests that Idaho Power Inc. (Company, Idaho
Power) provide the following documents and information as soon as possible, but no later than
WEDNESDAY, APRIL 1, 2015.r
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.
' Staffis requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at (208) 334-03 I 8.
SECOND PRODUCTION REQUEST
TO IDAHO POWER 1 MARCH 18,2015
This Production Request is to be considered as continuing, and Idaho Power 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.
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 identifu the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 34: Please provide supporting data for past, current, and projected
transmission uses by retail, wholesale, and generation customers served by Idaho Power via the
following asset transfers (See Application, JPSA, Exhibit A, p. A-2):
o Idaho to Northwest Transmission on the Hemingway - Summer Lake 500 kV line
o Idaho to Northwest Transmission on the Walla Walla - Hurricane 230 kV line
o Midpoint - Hemingway Transmission on the Midpoint - Hemingway 500 kV line
REQUEST NO. 35: Please explain changes to the projected first-year transmission
capacity deficit as a result of the asset exchange. Please explain why there are, or are not,
changes to the first-year transmission capacity deficit and provide a copy of the current
transmission capacity deficit projections.
REQUEST NO. 36: In response to Staff s Production Request No. 33, the Company
states there are "no anticipated changes to the cost and benefits of the proposed Boardman to
Hemingway project." Please explain how the asset exchanges and upgrades will have absolutely
no impact on the costs and benefits of the proposed Boardman to Hemingway (B2H) project.
REQUEST NO.37: The 2013 IRP found the B2H portfolio to be the lowest cost
portfolio (See 2013 Idaho Power Integrated Resource Plan, Table 9.2, p. 98). Please provide the
most current and up-to-date economic analysis of B2H that includes all costs and all benefits.
SECOND PRODUCTION REQUEST
TO IDAHO POWER MARCH 18,2015
REQUEST NO. 38: Please explain whether the current and most up{o-date B2H
economic analysis considers cost savings from the acquisition of the additional Hemingway -
Midpoint eastbound capacity (See Application, Dave Angell Direct Testimony, p. l5; and JPSA,
Exhibit A, p. A-2). If it does not, please explain.
REQUEST NO.39: Regarding the Company's response to Staff Production Request
No. 23, please provide a specific list of planned improvements to the Idaho to Northwest Path,
including a description of the transmission capacity impact. As part of the response, please
provide the transmission capacity prior to and following the asset exchange and improvements.
REQUEST NO. 40: Regarding the Company's response to Staff Production Request
No. 26, please provide a comparison of the transmission capacity prior to and following the asset
exchange for the three improvements listed.
DATED at Boise, Idaho, this I W day of March 2015.
Technical Staff: Johanna Belll3 4-40
Umisc/prod req/ipcel4.4ljac-e-14-l ldjhjbkls prodreq2 ipco
SECOND PRODUCTION REQUEST
TO IDAHO POWER
Daphne)Huang
MARCH 18, 2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF MARCH 2015,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NOS.
IPC-E-I4-41 /PAC-E-14-1I, 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. zuCHARDSON
RICHARDSON ADAMS PLLC
515 N. 27TH ST
BOISE, IDAHO 83702
E-MAIL : peter@richardsonadams. com
DANIEL SOLANDER
TED WESTON
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
ted.weston@p?cifi corp. com
DR. DON READING
6070 HILL ROAD
BOISE,IDAHO 83703
E-MAIL: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE