20150403PAC to Staff 28-31.pdf

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April 3, 2015
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
47 2 W est Wash i ngto n Street
Boise, ldaho 83702
Re: Case Nos. IPC-E-14-41and PAC-E-14-11
Exchange of Certain Transmission Assets - PacifiCorp's Response to the
Second Production Request of the ldaho Public Utilities Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matters please find an original and three (3)
copies of PacifiCorp's Response to the Second Production Request of the ldaho Public
Utilities Commission Staff.
Also enclosed are four (4) copies of a confidential disk containing information
responsive to Staff's production requests. Please handle the confidential information in
accordance with the Protective Agreement executed in this matter.
lf you have any questions about this filing, please contact Ted Weston, PacifiCorp
Manager of Regulation, at [phone] or me at [phone].
Very truly yours,
1221 W. ldaho 5t. (83702)
P.O. Box 70
Boise, lD 83707
JcW
Julia A. Hilton
JAH:csb
Enclosures
JULIA A. HILTON (lSB No. 7740)
ldaho Power Company
1221West 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 24OO
Salt Lake City, Utah 84111
Telephone: (801 ) 220-4014
Facsimile: (801 ) 220-3299
dan iel. so lander@pacifico rp. 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 TRANSMISSION ASSETS
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NOS.
'PC.E-14.41PAC-E-14-11
PACI FICORP'S RESPONSE TO
THE SECOND PRODUCTION
REQUEST OF THE IDAHO PUBLIC
UTILITIES COMMISSION STAFF
COMES NOW, PacifiCorp dlbla Rocky Mountain Power and Pacific Power
(collectively referred to as "PacifiCorp" or "Company"), and in response to the Second
Production Request of the Commission Staff to Rocky Mountain Power dated March 20,
2015, herewith submits the following information:
PACIFICORP'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 1
REQUEST NO. 28: ln response to Staffs Production Request No. 9 the
Company states that "PacifiCorp's Transmission Planning organization will continue to
perform ongoing reliability, load, and interconnection studies that identify future
transmission investments." Please provide copies of the most current transmission
planning studies for transmission Iines owner, or co-owned by PacifiCorp, extending into
and across ldaho, including the ldaho Northwest and Midpoint - Hemingway
transmission lines.
RESPONSE TO REQUEST NO. 28: Please refer to the below confidential
attachments provided on the confidentia! CD which contain the most recent
transmission planning studies.
o North American Electric Reliability TPL assessment (Attachment 1)o Load and Resource studies (Attachments 2-3)o System Operating Limit studies (Attachments 4-10)
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 J.D. Podlesnik, PacifiCorp,
and it is sponsored by Richard Vail, Vice President of Transmission, PacifiCorp.
PACIFICORP'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 2
REQUEST NO. 29: ln response to Staffs Production Request No. 33 the
Company referred to ldaho Poweds response which states that there are "no
anticipated changes to the cost and benefits of the proposed Boardman to Hemingway
project." Please explain whether PacifiCorp's most cunent and most up-to-date B2H
economic analysis considers the asset exchanges and upgrades. Please provide
PacifiCorp's most current and up-to-date economic analysis of B2H that includes all
costs and al! benefits.
RESPONSE TO REQUEST NO. 29: The Boardman to Hemingway analysis is
not affected by any aspects of the asset exchange. The Boardman to Hemingway
project will add capacity between the Northwest and Idaho. By contrast, the asset
purchase and sale agreement does not add capacity to the existing transmission
system and therefore does not change the cost or benefit of added capacity associated
with the Boardman to Hemingway project.
At this time, PacifiCorp is a signatory to the Boardman to Hemingway permitting
agreement and is committed to continue participation on the project as it supports
customer needs and system reliability. Due to the uncertainty of the Iine routes,
permits, and overall project timing, an in-depth analysis has not been completed at this
time.
The record holder for the response to this Request is Brian Fntz, PacifiCorp, and
it is sponsored by Richard Vail, Vice President of Transmission, PacifiCorp.
PACIFICORP'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 3
REQUEST NO. 30: Please explain any changes to PacifiCorp's projected first
year transmission capacity deficit as a result of the asset exchange. Please explain
why there are, or are not, changes to PacifiCorp's first year transmission capacity deficit
and provide a copy of the cunent transmission capacity deficit projections.
RESPONSE TO REQUEST NO. 30: Assuming transmission capacity deficit
means available transmission capacity, PacifiCorp does not gain or lose any
transmission capacity as a result of the asset exchange. Transmission planning does
not develop a transmission capacity deficit projection.
The record holder for the response to this Request is J.D. Podlesnik, PacifiCorp,
and it is sponsored by Richard Vail, Vice President of Transmission, PacifiCorp.
PACIFICORP'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 4
REQUEST NO. 31: In reference to Exhibit No. 8, p. 1, line 20, attached to the
direct testimony of PacifiCorp witness Richard Vail, please provide supporting
calculations for the estimated reduction in wheeling expense, along with whether the
estimated savings are associated with any of the specific transmission assets listed in
Exhibit C of the JOOA.
RESPONSE TO REQUEST NO. 31: As a result of the proposed asset exchange
with ldaho Power Company ("ldaho Power"), projected 2016 wheeling expense
associated with the Jim Bridger system would be reduced from $20.8 million to $17.1
million. Capacity purchased from ldaho Power will be reduced from 2,036 MW-year to
510 Mw-year. This is partially offset by an increase in ldaho Power transmission
service rates as a result of the proposed asset exchange. Details of the projected 2016
wheeling expense associated with the Jim Bridger system are described below.
Projected wheeling expenses for 2017 through 2025 are based on the same
assumptions but with the appropriate ldaho Power transmission service rate for each
year.
Projected 2016 wheeling expense without the proposed asset exchange is $20.8
million based on the following assumptions:
. $7.7 million for 1,586 MW of transmission capacity under the Restated
Transmission Services Agreement and Restated and Amended
Transmission Facilities Agreement between PacifiCorp and ldaho
Power.
. $6.1 million for 250 MW of transmission service at tariff rates under the
Interconnection and Transmission Service Agreement between
PacifiCorp and ldaho Power.
. $4.8 million for 200 MW of transmission service from Jim Bridger
Western Terminus to Midpoint.
PACIFICORP'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 5
$1.1 million for the use of ldaho Powe/s share of the 230 kV lines from
Bridger.
$1.1 million for short-term and non-firm transmission services capacity
purchased from ldaho Power.
ldaho Power transmission service rate of $24.25 per kW-year in 2016,
increasing to $33.52 per kW-yearin2025.
Projected 2016 wheeling expense with the proposed asset exchange is $17.1
million based on the following assumptions:
$11.2 million for 365 MW of transmission service from Borah/Kinport to
Enterprise.
$4.5 million for 145 MW of transmission service from Borah/Kinport to
La Grande.
. $1.4 million for short-term and non-firm transmission services capacity
purchased from ldaho Power. lncrease due entirely to higher ldaho
Power transmission service rate.
o ldaho Power transmission services rate of $30.76 per kW-year in 2016,
increasing to $43.08 per kW-year in 2025.
The record holder for the response to this Request is Brian Fritz, PacifiCorp, and
it is sponsored by Richard Vail, Vice President of Transmission, PacifiCorp.
DATED this 3d day of April 2015.
DANIEL E. SOLANDER" Attorney for Rocky Mountain Power
PACIFICORP'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 3'd day of April 2015 I served a true and correct
copy of PACIFICORP'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF
THE IDAHO PUBLIC UTILITIES COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attomey General
ldaho Public Utilities Commission
47 2 W est Washington (83702 )
P.O. Box 83720
Boise, Idaho 83720-007 4
PacifiCorp
Daniel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 24OO
Salt Lake City, Utah 84111
lndustrial Gustomerc 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
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PACIFICORP'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE IDAHO PUBLIC UTILITIES COMMISSION STAFF - 7
Christa Bearry, Legal Assistant