20130617Reply Comments.pdf

HO
PIlIER®
An IDACORP Company
2]i].iU!I :P1 t::148
LISA D.NORDSTROM
LeadCounsel L1
Inordstromcidahopower.com
June 14,2013
VIA HAND DELIVERY
Jean D.Jewell,Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise,Idaho 83702
Re:Case No.IPC-E-13-09
Glanbia Foods,Inc.’s Petition —Idaho Power Company’s Reply Comments
Dear Ms.Jewell:
Enclosed for filing in the above matter are an original and seven (7)copies of Idaho
Power Company’s Reply Comments.
In addition,an original and seven (7)copies of the confidential attachment are
enclosed in a separate envelope.Please handle the confidential attachment in accordance
with the Protective Agreement executed in this mailer.
Sincerely,
Lisa D.Nordstrom
LDN:csb
Enclosures
1221 W.Idaho St.(83702)
P.O.Box 70
Boise,ID 83707
LISA D.NORDSTROM (ISB No.5733)
JULIA A.HILTON (ISB No.7740)
Idaho Power Company 2J3 J H 1;:[3
1221 West Idaho Street (83702)
P 0 Box 70
Boise,Idaho 83707
Telephone:[phone]
Facsimile:[phone]
lnordstromidahopower.com
ihiItoncidahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
GLANBIA FOODS,INC.FOR APPROVAL
OF A LINE EXTENSION ALLOWANCE
PURSUANT TO IDAHO POWER
COMPANY’S RULE H.
Idaho Power Company (“Idaho Power”or “Company”)respectfully submits these
Reply Comments pursuant to Procedural Order No.32803 and in response to the
Comments filed by the Idaho Public Utilities Commission (“Commission”)Staff (“Staff’)
and Glanbia Foods,Inc.(‘Glanbia”)on June 5,2013.
Idaho Power believes that it cannot provide Glanbia with its requested allowance
under the Company’s current rules and tariff.The Company treated Glanbia’s request
for new transmission and substation facilities in a manner consistent with its rules,tariff,
and current Commission policy regarding these types of upgrades.It would be
inappropriate to provide an allowance to Glanbia without making a change to a rule or
tariff because the types of facilities it has requested are not eligible for allowances under
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Case No.IPC-E-13-09
IDAHO POWER COMPANY’S
REPLY COMMENTS
IDAHO POWER COMPANY’S REPLY COMMENTS -1
the Company’s existing tariff.Because there is no identified need for near-term
capacity in the area of Glanbia’s expansion,the Company determined that Glanbia’s
request does not provide a system benefit.Further,under the terms of Idaho Power’s
Open Access Transmission Tariff (‘OATT”),the Company would not be allowed to
charge a Vested Interest payment to transmission customers attaching to a
transmission line.
I.RULE H IS NOT APPLICABLE IN THIS CASE.
The Company maintains that the provisions of Rule H are not applicable to
Glanbia’s request for construction of a transmission line and substation.Staff and
Glanbia contend that Idaho Power should treat Glanbia’s request for the construction of
a transmission line as a request for the construction of distribution facilities.To support
their contention,Staff and Glanbia rely on the definition of a Distribution Provider as
defined by the North American Electric Reliability Corporation (“NERC”).NERC defines
a Distribution Provider as an entity that:
Provides and operates the “wires”between the transmission
system and the end-use customer.For those end-use
customers who are served at transmission voltages,the
Transmission Owner also serves as the Distribution
Provider.Thus,the Distribution Provider is not defined by a
specific voltage,but rather as performing the Distribution
function at any voltage.1
This NERC definition is not contained in the Company’s tariff and more
importantly does not define distribution facilities.The NERC document has never been
used as a basis for determining allowances to be provided by the Company on behalf of
customers.This complaint is not a question of whether or not Idaho Power is a
1 Glossary of terms used in Federal Energy Regulatory Commission’s Reliability Standards,
February 11,2013,at 23.
IDAHO POWER COMPANY’S REPLY COMMENTS -2
Distribution Provider,but whether or not the facilities being constructed should be
considered distribution facilities and appropriately considered under the definitions in
Rule H.
The same NERC document referenced by Staff and Glanbia defines a
Transmission Line as:
A system of structures,wires,insulators and associated
hardware that carry electric energy from one point to another
in an electric power system.Lines are operated at relatively
high voltages varying from 69 kV up to 765 kV,and are
capable of transmitting large quantities of electricity over
long distances.2
By this definition and consistent with the Company’s treatment of Glanbia’s
request,the 10-mile 138 kilovolt (‘ky”)line requested by Glanbia should clearly be
considered a Transmission Line.While NERC may maintain a glossary of terms that it
uses for establishing reliability standards,the Company abides by the provisions of its
Rule B tariff as the Commission-approved authority when defining a distinction between
its Secondary,Primary,and Transmission Service levels.3
II.COMPANY BETTERMENT IS NOT APPROPRIATE BECAUSE THERE ARE
NO NEAR-TERM NEEDS FOR ADDITIONAL CAPACITY IN THIS AREA.
In its Comments,Staff admits “it is clear that Rule H does not apply to
transmission or substation facilities,”4 but then argues that “nowhere is it stated in either
Rule H or Schedule 19 that no allowance must be provided for transmission or
2 Glossary of terms used in Federal Energy Regulatory Commissions Reliability Standards,
February 11,2013,at66.
I.P.U.C.No.29,Tariff No.101,Rule B Definitions,Original Sheet No.B-2.Rule B states that
Transmission Service is service taken at 44 kV or higher.Customers taking Transmission Service are
responsible for providing the transformation of power to the voltage at which it is to be used by the
Customer.”
Staff Comments at 3.
IDAHO POWER COMPANY’S REPLY COMMENTS -3
substation facilities.”5 This suggests that a new allowance provision could or should be
established for either or both transmission and substation construction.While no
allowance provision for such construction exists today,the Company does evaluate
requests for the construction of new transmission and substation facilities to determine if
any existing or anticipated new customers will benefit from the construction of such
facilities.Such benefit has been referred to as “Company Betterment.”6 In its review of
the Glanbia request,the Company identified no near-term system benefit to be derived
by existing or anticipated new customers.7 The Glanbia request solely benefits Glanbia.
Any allowance or betterment provided by the Company for transmission or substation
facilities that benefit only Glanbia would be eventually included in the rates paid by other
non-benefitting customers if such an allowance or determination of betterment was
established.The Company believes that such a determination in this case would be
inconsistent with the Commission’s desire to have the “cost causers”pay for the costs.8
The Company maintains that any Company contributions to the funding of transmission
lines and substations should be addressed via a determination of Company Betterment
rather than by establishing a new allowance provision.
Staff comments at 4.
6 I.P.U.C.No.29,Tariff No.101,Rule H New Service Attachments and Distribution Line
Installations or Alterations,First Revised Sheet No.H-i.Rule H states “Company Betterment is that
portion of the Work Order Cost of a Line Installation and/or Alteration that provides a benefit to the
Company not required by the Applicant or Additional Applicant.Increases in conductor size and work
necessitated by the increase in conductor size are considered a Company Betterment if the Connected
Load added by the Applicant or Additional Applicant is less than 100 kilowatts.If,however,in the
Company’s discretion,it is determined that the additional Connected Load added by the Applicant or
Additional Applicant,even though less than 100 kilowatts,is (1)located in a remote location,or (2)a part
of a development or project which will add a load greater than 100 kilowatts,the Company will not
consider the work necessitated by the load increase to be a Company Betterment.”
Attachment 1 hereto,Idaho Power Company’s response to Glanbia’s Request for Production
No.4.
8 Order No.30955 at 21.
IDAHO POWER COMPANY’S REPLY COMMENTS -4
III.GLANBIA AND STAFF CONFUSE THE PROVISIONS OF RULE H.
Rule H is the only location in the Company’s tariff that discusses allowances.
The Company believes the applicability of Rule H is clearly defined by the preface of the
Rule,which states:
This rule applies to requests for electric service under
Schedules 1,3,4,5,7,9,19,24,45,and 46 that require the
installation,alteration,relocation,removal,or attachment of
Company-owned distribution facilities.New construction
beyond the Point of Delivery for Schedule 9 or Schedule
19 is subject to the provisions for facilities charges
under those schedules.This rule does not apply to
transmission or substation facilities,or to requests for
electric service that are of a speculative nature.(Emphasis
added.)
The Company does not believe it should be necessary to again state within
Section 7,Line Installation and Service Attachment Allowance,of Rule H that the
allowances cannot be applied to offset the cost of transmission or substation facilities.
Further,the definitions of Line Installation and Line Installation Allowance limit the scope
to distribution facilities,as those definitions state a Line Installation is “any installation of
new distribution facilities owned by the Company”and a Line Installation Allowance is
“the portion of the estimated cost of a Line Installation funded by the Company.”9 There
is no tariff provision suggesting that it is appropriate to provide any allowance to offset
the cost of constructing transmission or substation facilities.Nonetheless,“Staff
believes it is fair and reasonable that the allowable investment be applied to whatever
facilities are needed to provide service whether they are terminal facilities,distribution
I.P.U.C.No.29,Tariff No.101,Rule H New Service Attachments and Distribution Line
Installations or Alterations,Original Sheet No.H-2.
IDAHO POWER COMPANY’S REPLY COMMENTS -5
facilities or transmission facilities.”10 As previously discussed,Rule H indicates
allowances are only to be used to offset the costs associated with distribution facilities.
IV.STAFF’S PROPOSED METHODOLOGY IS INAPPROPRIATE
AND CONTAINS COMPUTATIONAL ERRORS.
While the Company believes it is clear that Rule H is not applicable to Glanbia’s
request for the construction of a transmission line and substation and thus no allowance
is appropriate,it is important for the Company to comment on the inaccuracies
presented in Staff’s Comments regarding what allowances reflect and what they are
intended to recover.
Allowances provided for the construction of new distribution facilities under Rule
H are based on the cost of providing Standard Terminal Facilities.11 There is no
standard for terminal facilities that are typically required by Schedule 19 customers.
Industrial customers have a high degree of variability in the types of facilities required to
service their loads.Typically,it is necessary for these industrial/large load customers to
provide distribution facilities located beyond the primary point of delivery,a provision
10 Staff Comments at 6.
I.P.U.C.No.29,Tariff No.101,Rule H New Service Attachments and Distribution Line
Installations or Alterations,First Revised Sheet No.H-3.Rule H states,“Standard Terminal Facilities are
the overhead Terminal Facilities the Company considers to be most commonly installed for overhead
single phase and three phase services.Single phase Standard Terminal Facilities include the cost of
providing and installing one overhead service conductor and one 25 kVA transformer to serve a 200
amperage meter base.Three phase Standard Terminal Facilities include the cost of providing and
installing one overhead service conductor and three 15 kVA transformers to serve a 200 amperage meter
base.”
IDAHO POWER COMPANY’S REPLY COMMENTS -6
that is clearly outlined in Rule M12 and Rule B.13 Under the provisions of Rule M,if the
Company did install the distribution facilities beyond the primary point of delivery,the
customer would not be required to fund an upfront contribution in aid of construction
(“CIAC”)for those facilities but would instead pay the Company by means of a monthly
facilities charge.No allowances are provided under this alternative.
The “Case-by-Case”provision in Section 7 of Rule H14 is only appropriately
applied when a Schedule 19 customer requests terminal facilities that are not located
beyond the point of delivery.These Schedule 19 customers are typically Secondary
Service15 level customers.The terminal facilities for Schedule 19 Primary Service16
level customers,like Glanbia,are located beyond the point of delivery,and are not
covered under Rule H.
The Comments filed by Staff and Glanbia imply that Idaho Power has not treated
Glanbia in accordance with tariff provisions for Schedule 19 requests.Staff and Glanbia
12 •p•u•c•No.29,Tariff No.101,Rule M Facilities Charge Service,Original Sheet No.M-1
states,“Primary and Transmission Service level Customers not taking facilities charge services are
responsible for providing the transmission of power beyond the Point of Delivery needed to meet the
Customer’s service requirements.See Rule B.”
13 I.P.U.C.No.29,Tariff No.101,Rule B Definitions,Original Sheet No.B-2.Rule B states that
“Primary Service is service taken at 12.5 kilovolts (kV)to 34.5 kV.Customers taking Primary Service are
responsible for the transformation of power to the voltage at which it is to be used by the Customer.
Transmission Service is service taken at 44 kV or higher.Customers taking Transmission Service are
responsible for providing the transformation of power to the voltage at which it is to be used by the
Customer.”(Emphasis added.)
14 I.P.U.C.No.29,Tariff No.101,Rule H New Service Attachments and Distribution Line
Installations or Alterations,Fourth Revised Sheet No.H-i 1,7a.
I.P.U.C.No.29,Tariff No.101,Rule B Definitions,Original Sheet No.B-2.Rule B states that
“Secondary Service is service taken at 480 volts or less,or where the definitions of Primary Service and
Transmission Service do not apply.The Company is responsible for providing the transformation of
power to the voltage at which it is to be used by the Customer taking Secondary Service.”
16 The definition of Primary Service is included in footnote 13.
IDAHO POWER COMPANY’S REPLY COMMENTS -7
indicate there is a prescribed methodology for reducing a CIAC by means of an
allowance,and the Company has erred in not providing an allowance for Glanbia.
The Company’s methodology,proposed in Case No.IPC-E-08-22 (“the 2008
Rule H case”)was approved by the Commission in Order No.30853 and further
confirmed in Reconsideration Order No.30955.Staff’s proposed methodology in that
case was not adopted by the Commission.Nonetheless,Staff has used its unapproved
methodology as the basis for its comments in this case.The Company has reviewed
Staff’s analysis and concludes it is inappropriate for use in this case.
First,the Company does not agree with what it perceives as a blending of two
defined tariff terms,allowances and Company Betterment,into an undefined concept
referred to by Staff as an acceptable “allowable investment.”Nonetheless,the
Company has taken this opportunity to review the components that Staff has used to
determine an “allowable investment.”The Company believes Staff overlooked some
offsets to Company investments that would reduce Staff’s computation of the “allowable
investment”from $122 per kilowatt (“kW”)to $96 per kW.
Staff used an analysis consistent with that which it presented during the 2008
Rule H case to indicate that Glanbia is entitled to a $122 per kW allowance,stating that
“these amounts represent the level of investment for these facilities that is built into
rates.”17 After reviewing Staff’s calculation,the Company determined Staff had failed to
account for the substation CIACs that have offset plant investments in the past.That is,
the CIACs provided by Schedule 19 customers in the past have effectively reduced the
investment or rate base of the Company.Correcting for this omission reduces Staff’s
calculation by roughly $22/kW.Staff also included plant associated with providing
17 Staff Comments at 6.
IDAHO POWER COMPANY’S REPLY COMMENTS -8
meters,which is incorrect because these facilities are not included in the upfront cost a
customer pays.If the Company provided an allowance for meters,when the associated
cost is not included in the upfront customer charge,it would provide an offset twice.
Reducing the plant by the cost of the meters resulted in an additional $4/kW reduction.
Replicating Staff’s methodology to calculate a per kW cost of distribution plant
embedded in Schedule 19 rates,the Company calculated an amount of approximately
$96/kW.
The Company also disagrees with Staff’s statement that an allowance should be
able to offset jy facilities needed to receive service,even if they are transmission
facilities.The Company believes it is inappropriate to calculate an allowance based on
distribution facilities and then use that allowance to offset investment in transmission
facilities.Glanbia’s request for service does not include distribution facilities that
would be covered under Rule H,or eligible for an allowance.Furthermore,none of the
Company’s allowances that are approved under Rule H are based on a per kW basis,
and the Company supports this because it believes it is inappropriate to base an
allowance on an anticipated load that may or may not materialize.
Staff’s Comments state,“Idaho Power’s proposed allowances were not based on
an analysis of embedded costs,but seemed instead to be based simply on policy.”18
Idaho Power agrees with Staff;the Company’s allowances were not based on an
embedded rate methodology,but were primarily based on a shift in policy and more
specifically a change to the cost of Standard Terminal Facilities.The Company’s
allowances were approved in Order Nos.30853 and 30955,which authorized the policy
shift from an embedded rate methodology to one based on the cost of Standard
18 Staff Comments at 5.
tDAHO POWER COMPANY’S REPLY COMMENTS -9
Terminal Facilities.In the current case,Staff implies that because the Idaho Power
proposed and Commission-approved allowances were close to what Staff’s own
calculations were,that effectively meant the Commission approved Staff’s analysis in
Case No.IPC-E-08-22.19 The Company disagrees.The Building Contractors
Association filed for reconsideration on the grounds that the Commission did not uphold
the “embedded-rate”methodology that was established during the 1995 Rule H case,
and in its Order No.30955,the Commission stated:
The Contractors first assert that our recently approved
changes to Rule H are inconsistent with the methodology
that the Commission adopted in the 1995 Rule H case.BCA
implied that the Commission cannot change its methodology
from the 1995 case.We reject this argument.2°
It appears that Staff has attempted to reintroduce an embedded cost
methodology that was not approved by the Commission.
V.THE OATT DOES NOT ALLOW FOR VESTED INTEREST PAYMENTS
FOR TRANSMISSION CUSTOMERS.
The Company’s OATT approved by the Federal Energy Regulatory Commission
(“FERC”)does not provide for or allow the Company to impose a vested interest charge
on any transmission customer or generator21 that is interconnecting to Idaho Power’s
transmission system under the provisions of the OATT.The Company’s generator
interconnection process is governed by the FERC-approved large and small generator
interconnection procedures set forth in Attachment M and N of the OATT (“OATT
Interconnection Procedures”).The OATT Interconnection Procedures include,inter alia,
19 Staff comments at 5.
20 Order No.30955 at 21.
21 Public Utility Regulatory Policies Act of 1978 Qualified Facility interconnections are state
jurisdictional and are controlled by the I.P.U.C.No.29,Tariff No.101,Schedule 72 Interconnections to
Non-Utility Generation.
IDAHO POWER COMPANY’S REPLY COMMENTS -10
provisions that allocate costs and charges associated with interconnection with Idaho
Power’s transmission system.
Idaho Power’s OATT Interconnection Procedures do not include a vesting
interest component.As a consequence,Idaho Power cannot apply the vested interest
component proposed by Glanbia without a FERC-approved amendment to the OATT
Interconnection Procedures.To obtain FERC approval,Idaho Power would be required
to satisfy FERC regulation and policy.In particular,Idaho Power would be required to
demonstrate that the vested interest component was just and reasonable,non
discriminatory,and not a barrier to access to the transmission system,or otherwise
result in adverse impacts to FERC customers or the Company.The OATT
Interconnection Procedures,including the cost allocations included therein,were
developed at FERC through a significant process where cost issues were considered
and debated at length.The introduction of a new concept related to cost allocation
outside the established OATT Interconnection Procedures that would potentially impact
a number of existing or potential customers would likely involve significant stakeholder
intervention and increased FERC scrutiny.
Glanbia requests “access to the full nameplate capacity of the expansion it pays
for.”22 While the transmission line and substation that would be built to serve the
Glanbia load is owned,operated,and maintained by the Idaho Power,the Company
understands the concern Glanbia may have regarding the availability of capacity at the
time its load comes to fruition.As stated before,the Company does not anticipate any
additional load in that area in the near future and,consequently,more than adequate
capacity should be available when needed.However,it is not an optimal use of the
22 Glanbia Comments at 4.
IDAHO POWER COMPANY’S REPLY COMMENTS -11
Company’s system to maintain capacity indefinitely,potentially causing other customers
to pay for system capacity when capacity already exists.As a general rule,the
Company’s practice is to maintain capacity for a project that has been funded by an
offsetting CIAC for a reasonable period of time,even if additional claims on that
capacity are requested.The typical amount of time that has been considered a
reasonable amount of time is a five-year period.This assurance should alleviate
Glanbia’s concerns.
VI.THE COMPANY HAS BEEN CONSISTENT IN TREATMENT
OF SCHEDULE 19 CUSTOMERS.
The requirement that Glanbia fund a CIAC for the cost of the transmission and
substation facilities requested to service its load is consistent with the Company’s
treatment of all Schedule 19 Large Power Service customers.Requiring customers to
fund these types of facilities upfront protects the entire customer class from uncertainty
or speculation associated with the requested load of a single customer not coming on
line.Other Schedule 19 customers should not have to pay for facilities required to
provide service for a single customer,in this case,Glanbia’s expansion.
While the record is voluminous,the Company feels that direct testimony in Case
No.IPC-E-OO-1223 submitted by Commission Staff witness Rick Sterling and direct and
rebuttal testimony submitted by Company witness Greg Said is relevant in considering
the current Petition.During that case,Mr.Sterling maintained that “Rule H very clearly
states that it does not apply to transmission or substation facilities.Therefore,Rule H
does not apply since this complaint concerns costs associated with the Bethel Court
23 Case No.IPC-E-OO-1 2,Kimball Properties Limited Partnership,and Hewlett-Packard
Company,Complainants vs.Idaho Power Company,an Idaho Corporation,Respondent.
IDAHO POWER COMPANY’S REPLY COMMENTS -12
substation."2a Mr. Sterling testified that ldaho Power had not violated any of its rules or
its tariff when it required the proposed Schedule 19 customer to fund a portion of the
substation and, in fact, Mr. Sterling noted:
Customers could request service and possibly trigger
construction of new facilities to serve the ultimate maximum
load expected, and face no consequences if only a part of
the load (and revenue that goes along with it) materialized
.no,ulJ:ll","r:[,XlJl:'E[,:"H'i;:l,1'ffi ,l313;il]"#
Power.2s
ln his testimony, Mr. Sterling also stated that the treatment of Schedule 19
customers was "inconsistent and discriminatory,"26 because "it is discriminatory
whenever one customer has to pay for substation facilities and another customer, who
may require the same or even larger substation capacity, does not have to pay just
because extra substation capacity is atready availabte."27 On Rebuttal, Company
witness Mr. Said responded to Mr. Sterling's statement by pointing out that:
A new customer who requires no additiona! facilities
provides a benefit to other ldaho Power customers in that no
additional costs are added to the system, but the existing
costs can be spread across a greater load, thereby
effectively reducing the cost responsibility of other customers
Conversely, a new customer who requires additional
facilities, but is not required to make a CIAC, adds total costs
to be recovered by the Company. Those additional costs
adversely impact existing customers^, since those customers
must absorb those additional costs.28
'o Case No. IPC-E-00-12, Sterling Direct Testimony, Tr. at 131.
2s Case No. IPC-E-00-12, Sterling Direct Testimony, Tr. at137.
'u Case No. IPC-E-00-12, Sterling Direct Testimony, Tr. a|143.
27 ld.
" Case No. IPC-E-00-12, Said Rebuttal Testimony, Tr. a|277.
IDAHO POWER COMPANY'S REPLY COMMENTS - 13
The Company continues to agree this is good regulatory policy,and it has treated
Glanbia according to the principles outlined during Case No.IPC-E-00-12 and
subsequently approved in Order No.29529.It is noteworthy that when Glanbia first
came on-line,Glanbia was served out of a substation with existing capacity and was not
required to fund a CIAC.The requested facilities in this case are only being built
because of Glanbia’s increased load;the Company would not be building a new
transmission line or substation were it not for Glanbia’s request.
The Commission had an opportunity to review the record from Case No.IPC-E
00-12 in its entirety and in its Final Order stated,“The Commission supports the
payment of contributions in aid of construction as such payments directly offset
Company investment and additions to rate base.”29 The Company believes this policy is
consistent with and supported by more recent Commission rulings,where the
Commission stated,“To the extent practicable,utility costs should be paid by those that
cause the utility to incur the costs.If the “cost-causers”do not pay,the electric rates for
other customers will be higher.”3°
VII.CONCLUSION
Idaho Power’s existing rules and tariff do not provide for the allowance as
requested by Glanbia.The Company believes that a change as proposed by Glanbia
and Staff would require tariff changes,the full impacts of which have not been
completely addressed in this complaint case.The Company acted in accordance with
its tariff and rules regarding its treatment of Glanbia.The Company’s tariff does not
contain provisions for determination of an “allowable investment”by the Company.In
29 Order No.29529 at 6.
°Order No.30955 at 21.
IDAHO POWER COMPANY’S REPLY COMMENTS -14
addition,the Company’s tariff does not contain any provision for allowances to be
provided for the construction of either transmission or substation facilities.Moreover,
The Company’s tariff only envisions allowances to be provided for the construction of
new distribution facilities.Glanbia has requested construction of transmission and
substation facilities.No existing or anticipated new customer will directly benefit as a
result of Glanbia’s request for the construction of transmission and substation facilities.
Due to the reasons described in more detail above,Glanbia’s Petition for Approval of a
Line Extension Allowance Pursuant to Idaho Power’s Rule H Tariff should be denied.
Dated at Boise,Idaho,this 14th day of June 2013.
JULIA A.HILION
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S REPLY COMMENTS -15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of June 2013 I served a true and
correct copy of IDAHO POWER COMPANY’S REPLY COMMENTS upon the following
named parties by the method indicated below,and addressed to the following:
Commission Staff X Hand Delivered
Weldon Stutzman
____U.S.
Mail
Deputy Attorney General
____Overnight
Mail
Idaho Public Utilities Commission
____FAX
472 West Washington (83702)X Email WeIdon.Stutzman(äpuc.idaho.çov
P.O.Box 83720
Boise,Idaho 83720-0074
Glanbia Foods,Inc.
____Hand
Delivered
PeterJ.Richardson X U.S.Mail
Gregory M.Adams
____Overnight
Mail
RICHARDSON &O’LEARY,PLLC
___FAX
515 North 27th Street (83702)X Email peter(richardsonandolearv.com
P.O.Box 7218 greqcrichardsonandoleary.com
Boise,Idaho 83707
()A Qu±
hrista’Bearry,LdjäTAsfstant
IDAHO POWER COMPANY’S REPLY COMMENTS -16
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC-E-13-09
IDAHO POWER COMPANY
ATTACHMENT I
REQUEST NO.4:At page 10,Idaho Power’s Petition provides:
The Company considered whether granting Glanbia some
Company Betterment amount would be appropriate in this instance,
but after reviewing its load forecast for the area,the Company
concluded that there is no indication for additional capacity needs in
that substation in the near term.
Please provide a copy of the “load forecast for the area”relied on to support the
conclusion reached in that sentence along with all workpapers and supporting
documents used to prepare the same.
RESPONSE TO REQUEST NO.4:The “load forecast for the area”that was
relied on to support the conclusion is provided in the confidential Excel file,provided on
the confidential CD,with the tab labeled ‘Toponis T131 Forecast.”This forecast
identified that a system improvement would not be required until 2022,at the earliest,
which is beyond the five-year near-term planning horizon.The confidential CD will be
provided to those parties that have executed the Protective Agreement in this
proceeding.
Upon further consideration of the request for Company Betterment,a second
forecast,provided in the “Toponis T131 less Glanbia Fcast”tab,was developed based
on the assumption that the Glanbia facility would be served from a new substation.In
this forecast,the Glanbia load was removed from the forecast starting year and from the
growth rate calculation.This forecast results in a maximum loading of 72 percent in
year 2026 and demonstrates the anticipated low utilization of the existing Toponis
facilities following the transfer of Glanbia from this station.
Background -The confidential Excel file is a load forecasting tool that is used by
Idaho Power regional planners.Row 4 of the spreadsheet “Toponis TI 31 Forecast”tab
IDAHO POWER COMPANY’S RESPONSE TO GLANBIA FOODS,INC.’S,FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER -11
lists the substation transformer peak demand measurements,in kilowatts (“kW”),over
the last ten years.The annual number of customers served from the transformer is
provided in Row 5 of the spreadsheet “Toponis T131 Forecast”tab.Growth rates
based on the past five and ten year periods are calculated using embedded formulas in
cell B8 through C9 of the spreadsheet “Toponis T131 Forecast”tab.Load may vary
greatly from year to year as it is dependent on many factors including but not limited to:
weather,load diversity,crop rotations,irrigation patterns,and economic development.
All of these factors can impact the peak loading and are taken into consideration when
forecasting future demand.Therefore,the planner uses the historical load and
customer growth as well as local knowledge of the area and its growth possibilities to
determine a growth rate that best fits the area and is entered into BIO of the
spreadsheet “Toponis TI 31 Forecast”tab.
Generation located on the distribution feeders served by the substation
transformer must also be accounted for when forecasting the loading.This particular
area has seven generators connected to the distribution feeders.The power output of
these generators at the time of the transformer peak demand may also vary.The
planner includes the outage of the largest generator in the forecast to reduce the
possibility of under-forecasting the peak demand.The peak output of the largest
generator is added to the demand as shown in the spreadsheet cell H30 of the
spreadsheet “Toponis T131 Forecast”tab.
Based on the existing transformer loading,Idaho Power has identified a project
to transfer 1200kW of peak load from one of the Toponis feeders to a Gooding Rural
Substation feeder.This forecasted transformer loading reduction is included in cell H33
IDAHO POWER COMPANY’S RESPONSE TO GLANBIA FOODS,INC.’S,FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER -12
of the spreadsheet “Toponis TI 31 Forecast”tab.The project will be implemented when
the Toponis transformer is forecasted to exceed the substation transformer replacement
criteria.Idaho Power replaces substation transformers before they reach 98 percent of
their nameplate capacity rating.The forecasted implementation year for this project is
2020 based on the present Glanbia peak loading.
The response to this Request was prepared by Dave Angell,Delivery Planning
Manager,Idaho Power Company,in consultation with Lisa D.Nordstrom,Lead
Counsel,Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO GLANBIA FOODS,INC.’S,FIRST
PRODUCTION REQUEST AND REQUEST FOR ADMISSIONS TO IDAHO POWER -13
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