20230309Staff 1-17 to Rocky Mountain.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )ROCKY MOUNTATN POWER FOR A )CASE NO.PAC-E-23-01
CERTIFICATE OF PUBLIC CONVENIENCE )AND NECESSITY AUTHORIZING )CONTRUCTION OF THE BOARDMAN-TO-)FIRST PRODUCTION
HEMMINGWAY 500-KV TRANSMISSION )REQUESTOF THE
LINE PROJECT )COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy AttorneyGeneral,requests that Rocky Mountain Power provide the
followingdocuments and information as soon as possible,but no later than
THURSDAY,MARCH 30,2023.
This Production Request is to be considered as continuing,and Rocky Mountain 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 or information
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
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MARCH 9,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUESTNO.1:In its Application,the Company describes a complex plan with
many projects and transactions that are distinct from constructing the Boardman to Hemingway
("B2H")transmission line.The followingare a list of projects and transactions Staff has
identified in the Application:
I.Pre-B2H Agreements:
a.Establish the 2nd amended and restated Joint Permit Funding Agreement;
b.The Company will renew its 510 megawatts ("MW")of point to point ("PTP")
transmission service from Idaho Power Company ("IPC");
c.Bonneville Power Association ("BPA")will redirect and assign to the Company
200 MW of PTP transmission rights it holds on IPC's system;
d.The Company and BPA will amend the Midpoint-MeridianAgreement and
update multiplePTP service agreements concerning central Oregon load service;
e.Establish the Longhorn Substation Funding Agreement;
f.IPC will acquire 500 MW of PTP transmission service from BPA between Mid-C
and Longhorn;and
g.IPC and BPA will establish a Purchase,Sale,and Security agreement,and two
related transmission agreements,to buy out BPA's permitting interest.
II.The B2H Core Project:
a.Establish the Joint Construction Funding Agreement with IPC;
b.Acquire rights-of-way;
c.Construct access roads,the main transmission line,and communication stations;
d.Rebuild or remove certain other transmission segments;
e.Construct the Longhorn substation;
f.Upgrade the Hemingway substation;and
g.Construct the Midline Series Capacitor substation.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MARCH 9,2023
III.Asset Exchanges and Related Construction Agreements with IPC:
a.IPC transfer to the Company transmission assets between Midpoint and Borah for
300 MW west-to-east capacity;
b.IPC transfer to the Company transmission assets between Borah and Hemingway
for 600 MW east-to-west capacity;
c.The Company transfer to IPC transmission assets between Populus and Four
Corners for 200 MW of bi-directional capacity;
d.The Company transfer to IPC identified Goshen area assets;
e.Establish a construction agreement and construct the Midpoint 500/345-kV
Transformer Project;and
f.Establish a construction agreement and construct the Kinport-Midpoint345-kV
Series Capacitor Bank Project.
For each of these projects or transactions above (and any others inadvertentlyomitted by Staff),
please provide the following:
1.Please identify which of these projects/transactions that the Company is seeking
Commission authorization under the Certificate of Public Convenience and
Necessity ("CPCN").
2.Please identify which of these projects/transactions the Company is seeking
Commission authorization of in this case but not specifically under the CPCN.
3.Please identify which of these projects/transactions the Company plans to seek
Commission authorization of outside of this case.If seeking authorization outside
of this case,when and how will the Company be seeking authorization?
4.For any projects/transactions that will be authorized outside of this case,please
discuss possible dependencies between them and the included
projects/transactions.
REQUESTNO.2:Please provide detailed and legible project maps portraying the
operational components (substations,lines,etc.)and proposed transfer components,as described
in agreements between the Company and its partners.Please indicate the name,physical
location,agreement reference(s),and ownership for each component on each map.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 MARCH 9,2023
REQUESTNO.3:Please provide the followingscope and cost estimate information:
a.Please provide a tabulated comparison of the project scope and cost that were
assumed in the Updated 2021 Integrated Resource Plan ("IRP"),and the scope
and cost that are currentlyincluded in the Boardman to Hemingway project [as
defined by the Joint Construction Funding Agreement ("JCFA")];
b.In addition to the previous comparison,please provide a detailed list of the project
scope included in the JCFA and the associated costs.Please include any associated
accounting costs -such as the Allowance for Funds Used During Construction
("AFUDC")-to provide a comprehensive summary of the total project cost.Also,
please indicate the Company's share of the total project cost;and
c.Please provide a list of any B2H-related costs that are outside of the JFCA,such
as the series capacitor bank at the Meridian substation.Link Direct at 25.
REQUESTNO.4:Table 4 in Company Witness Link's testimony identifies the costs
and benefits of B2H.Link Direct at 33.Please provide the following:
a.Please explain and provide the worksheet(s)showing how the Company
determined the net cost for B2H to be $454 million;
b.Please explain and provide the worksheet(s)showing how the Company
determinedthe net cost for Asset and Reservation Exchange to be $308 million;
c.Please explain and provide the worksheet(s)showing how the Company
determined the net benefit for System Dispatch Impacts in the "MM"scenario to
be $520 million;and
d.Please explain and provide the worksheet(s)showing how the Company
determined the net benefit for Central Oregon Load Service to be $1,811 million.
REQUESTNO.5:Company Witness Link testifies that "In the absence of B2H,
providing this level of central Oregon load service would require at least 725 MW of
dispatchable generationin southern Oregon."Link Direct at 25.
a.Please explain why the Company expects loads to grow from 340 MW to 680
MW in central Oregon.Link Direct at 25;
FIRST PRODUCTIONREQUEST
TO ROCKY MOUNTAIN POWER 4 MARCH 9,2023
b.Please explain why this growth will require at least 725 MW of dispatchable
generation;
c.Please provide the "non-wires analysis performed by BPA,IPC,and PacifiCorp"
described in footnote 14 of this testimony.Link Direct at 25;and
d.Please explain how the Company estimates the annual fixed costs of this resource
to be $230 million in 2027.Link Direct at 26.
REQUESTNO.6:Company Witness Link testifies that "...BPA will redirect and then
assign to PacifiCorp 200MW of PTP transmission rights it holds on IPC's system."Link Direct
at 37.Please provide the following:
a.Please provide a detailed explanation of the need for this agreement;
b.Please provide maps portraying the existing and proposed PTP routes;and
c.Please explain the Company's contingency plan if this exchange is prevented or
not implemented.
REQUESTNO.7:Company Witness Vail testifies that "...BPA will be responsible for
designing,procuring,and constructing the Longhorn substation...."Vail Direct at 6-7.He also
testifies that "The [Longhorn Substation Funding Agreement]will be contingent upon BPA
completing its obligations and responsibilities under various environmental compliance laws."
Vail Direct at 29.Please explain the following:
a.Please itemize the responsibilities that BPA must complete and identify any that
pose a significant degree of risk or uncertainty;
b.Please list the estimated timeline for BPA to complete its responsibilities;and
c.Please describe the Company's contingency plan if BPA is unable to complete its
responsibilities.
REQUESTNO.8:Company Witness Vail testifies that "B2H is necessary for the
Company to meet its customers'short-and long-term energy demand..."Vail Direct at 4.
Please provide the following:
a.Please provide the Company's 20-year Load &Resource Balance ("L&RB")
showing the year and deficits justifying this need.Please ensure this information
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 MARCH 9,2023
clearly identifies the deficits in central Oregon and in the vicinity of Longhorn
substation;
b.Please explain how the Company will serve its customers if B2H is not approved;and
c.Please explain how the Company will serve its customers if B2H is approved but
completion is delayedbeyond any deficit date.
REQUESTNO.9:The Company states that "...BPA decided to transition out of its role
as a joint permit funding coparticipant."Application at 6.Please explain why BPA wanted out
of its role.Please explain why IPC is buying out BPA instead of the Company,or instead of
both companies sharing the buyout.
REQUESTNO.10:Please explain all potential fundingsources the Company has
considered and pursued to finance B2H by answering the following:
a.Has the Company pursued available Federal funds for grid resilience and
transmission?If not,why not?If yes,please describe the funds available,status
of funding pursued,and how these funds potentiallyreduce impact to ratepayers;
b.Has the Company pursued available State funds through the Office of Energy and
Mineral Resources ("OEMR")?If not,why not?If yes,please describe the funds
available,status of funding pursued,and how these funds potentiallyreduce
impact to ratepayers;
c.Has the Company pursued funds through the Federal Emergency Management
Agency ("FEMA")and the Office of Emergency Management ("OEM")?If not,
why not?If yes,please describe the funds available,status of fundingpursued,
and how these funds potentiallyreduce impact to ratepayers;
a.Has the Company applied for any grants or other fundingfor the project?If so,
what were the sources,amounts,and application dates;and
a.Has the Company been awarded any grants or other fundingfor the project?If so,
what were the sources,amounts,and dates awarded?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 MARCH 9,2023
REQUESTNO.11:Company Witness Vail testifies that there are additional asset
exchanges proposed between IPC and the Company that are related to B2H but are separate from
the main B2H project.Vail Direct at 21-24.For the four proposed asset exchanges,please
provide the following:
a.Please explain the interdependencies of each exchange with each other and with
the B2H project;and
b.Please explain the Company's contingency plans if any of the asset exchanges are
prevented or not implemented.
REQUESTNO.12:Please describe how the Company will monitor IPC's construction
progress and costs for the B2H project.Please provide any supporting documents.
REQUESTNO.13:Please describe how the Company will allocate project costs to
Idaho customers.Please provide supporting documents that describe the Company's cost
allocation policies.
REQUESTNO.14:Please describe the Company's current Idaho load.Please explain
the benefits the proposed B2H project will confer to Idaho customers.Please provide supporting
workpapers.
REQUESTNO.15:From the Exhibit 2 tab "Study Detail",please explain the eight pre-
B2H requirements under the section "Load Interconnection".
a.Please explain if these requirements are included in the B2H construction project;and
b.If so,please explain how costs will be shared between the Company and partners.
REQUESTNO.16:Company Witness Link describes the proposed Ozone Transport
Rule and its requirements of the Company's thermal facilities in Utah and Wyoming.
a.Please quantify the amount of electricity from the Company's Utah and Wyoming
thermal facilities that meets the requirements of the proposed Ozone Transport
Rule that can be transmitted on the proposed B2H transmission line;and
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 MARCH 9,2023
b.Please provide supporting workpapers that include the yearly requirements from
the proposed rule and the corresponding impact on the Company's production
levels from Utah and Wyoming thermal facilities.
REQUESTNO.17:Company Witness Link referred to a study on the proposed Ozone
Transport Rule effects.Link Direct at 21.
a.Please explain if the study will include an evaluation of the Rule's impact on
Idaho costs;and
b.Please provide the expected timeline for the study to be completed.
DATED at Boise,Idaho,this day of March 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umisc:prodreq/pace23.lcbms prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 MARCH 9,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9th DAY OF MARCH 2023,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOROCKYMOUNTAINPOWER,IN CASE NO.
PAC-E-23-01,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MARK ALDER JOHN HUTCHINGSROCKYMOUNTAINPOWERCARLASCARSELLA
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWERSALTLAKECITYUT841161407WESTNORTHTEMPLE STE 330E-MAIL:[e-mail] SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
[e-mail]
DATA REQUEST RESPONSE CENTER KATHERINE McDOWELL
E-MAIL ONLY:ADAM LOWNEY
[e-mail] McDOWELL RACKNER GIBSON
419 SW 11TH AVE STE 400
PORTLAND OR 97205
E-MAIL:[e-mail]
[e-mail]
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK &OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL:lance aegisinsight.comE-MAIL:[e-mail]
THOMAS J BUDGE BRIAN C COLLINS
RACINE OLSON PLLP GREG MEYER
PO BOX 1391 BRUBAKER &ASSOCIATESPOCATELLOID83204-1391 16690 SWINGLEY RIDGE RD,#140
E-MAIL:ti racineolson.com CHESTERFIELD MO 63017
E-MAIL:[e-mail]
[e-mail]
SECRE Y
CERTIFICATE OF SERVICE