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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP D/B/A ROCKY
MOUNTAIN POWER AND IDAHO POWER
COMPANY EOR AN ORDER AUTHORIZTNG
THE EXCHANGE OF CERTAIN
TRANSMTSSION ASSETS.
CASE NO. IPC-E-14-41
CASE NO. PAC-E-14-11
PACIFICORP
DIRECT TESTIMONY
OF
RICHARD A. VAIL
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I. INTRODUCTION A}ID EXPERIENCE
O. Pl-ease state your name and business address.
A. My name is Richard A. Vail. My business
address is 825 NE Multnomah Street, Portland, Oregon 91232.
O. In what position are you currently employed?
A. I am the Vice President of Transmi-ssion for
PacifiCorp ("Company"). I have been employed with
PacifiCorp since 200L.
Please describe your educatj-on and busj-ness
exper]-ence.
A. I have a Bachelor of Science degree with
Honors in El-ectrical Engineering with a focus in electric
power systems from Portland State University. I have been
Vice President of Transmission for PacifiCorp since
December 20L2. Before my current position in Transmission,
I was director of asset management since 2001. Before that
position, I had management responsibility for a number of
organizations in PacifiCorp's asset management group,
including capital planning, maintenance policy, maintenance
planning, and investment planning since joinlng PacifiCorp
j-n 2001,. In my current role as Vice President of
Transmission, I am responsible for transmj-ssion system
planning, customer generator interconnection requests and
transmission service requests, regional transmissj-on
initiatives, capital budgeting for transmission, and
VAIL, DIPacifiCorp
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administration of the Open Access Transmission Tariff
(*oATT").
o.
A.
hlhat j-s the purpose of your testimony?
The purpose of my testimony is to provide an
(1)overview of this transaction, including the following:
the purpose of and need for the asset exchange; (2)
reliability and operational benefits of the exchange for
PacifiCorp's customers; and (3) financial implications of
the asset exchange.
II. OEHER TESTIMONY SUPPORUNG THIS FILING
O. Are any other individuals filing testimony on
behalf of PacifiCorp in this proceedj-ng?
A. Yes. The followj-ng individual is providing
testimony on behalf of PacifiCorp:
o Gregory N. Duval-I, Director, Net Power
Costs, has prepared testimony supporting PacifiCorp
Energy's new firm transmission rlghts following the close
of the transaction and associated benefits.
o.Are any other individuals filing testimony in
this proceeding?
A. Yes. The following individuals are providing
testimony on behalf of Idaho Power Company ("Idaho Power")
in this proceeding:
o Lisa A. Grow, Senior Vice President of
Power Supp1y, has prepared testimony supporting the
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transactlon and describing the background and benefits from
the transaction.
o David M. Angell, Planning Manager, has
prepared testimony discussing the new ownership rights
resulting from the transaction and describing the assets
and capacity being exchanged.
III. DESCRIPTION OE PACIFICORP
O. Pl-ease provide a description of PacifiCorp.
A. PacifiCorp is an indirect, who1ly-owned
subsidiary of Berkshire Hathaway Energy Company.
PacifiCorp provides delivery of electric power and energy
to approximately 1.8 million retail electric customers in
six western states. PacifiCorp consists of three core
business units: (1) PacifiCorp Energy, which manages the
el-ectric generation, commercj-al- and trading, and coal
mj-ning operations of the Company; (2) Pacific Power, which
delivers electricity to retail customers in Oregon,
Washington, and California; and (3) Rocky Mountain Power,
which delj-vers electricity to retail customers in Utah,
Wyoming, and Idaho. PacifiCorp's transmission operations
and management personnel are headquartered in Portland,
Oregon.
Under its OATT, PacifiCorp provides Long-Term Firm
Point-to-Point ("PTP") Transmission Service to 11-
transmission customers, Short-Term Firm and Non-Firm PTP
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Transmission Service to 73 transmission customers under
umbrell-a service agreements, and Network IntegratJ-on
Transmission ("NIT") Service to 11 transmj-ssion customers,
including PacifiCorp Energy.
As of December 31, 20L3, PacifiCorp's total-
transmission plant in service is approximately $5.2
billion. PacifiCorp is interconnected, controls, ox meters
approximately L20 generation plants within its Balancing
Authorj-ty Areas ("BAAs") and is adjacent to 11 BAAs at
approximately 717 points of interconnection. PacifiCorp
owns, or has an interest in, generatj-on resources directly
interconnected to its transmission system with a net
generating capacity of 10r 595 megawatts (*MW") . This
generation capacity includes a dj-verse mix of coa1,
hydroelectric, wind, natural gas-fired combined cycle and
combustion turbines, solar, and geothermal resources.
o.Please describe PacifiCorp's transmission
system.
A.PacifiCorp's bulk transmission network is
desi-gned to reliably transport electric energy from
generation resources (owned generation or market purchases)
to various load centers. The Company's transmission
network is highly integrated with other transmissj-on
provj-ders in the western United States. PacifiCorp owns
and operates 161 300 miles of transmission lines in 10
VAIL, DIPacifiCorp
1 states. PacifiCorp operates two BAAs referred to as
2 PacifiCorp's east Balancing Authority Area ('PACE") for
3 PacifiCorp's east BAA and PacifiCorp's west Balancing
4 Authority Area ("PACW") for PacifiCorp's west BAA. Bxhibit
5 No. 6 provides a high-1evel- map of PacifiCorp's
6 transmissj-on system and servj-ce territory.
1 Q. Which state pubJ-ic utility commissj-ons
8 regulate PacifiCorp's retail service operations?
9 A. PacifiCorp is subject to the jurisdiction of
10 the following six state public utility commissions: (1)
11 California Public Utilities Commission; (2) Idaho Public
L2 Utilities Commission; (3) Pub1ic Utility Commission of
13 Oregon, (4) Public Service Commission of Utah; (5)
14 Washington Util-ities and Transportation Commission; and (6)
15 Wyoming Public Service Commission.
1,6 IV. DESCRIPTTON OE FILING
71 O. Pl-ease describe the transaction.
18 A. As detaj-l-ed in the Application, PacifiCorp and
1,9 Idaho Power agree to acquire ownership interests in certaj-n
20 existing transmission system assets, ds well as reallocate
2! respective ownership interests in certain jointly-owned
22 facilities. In summary, the Parties have entered into a
23 transaction under the Joint Purchase and Sale Agreement
24 ("JPSA") that effectuates an exchange of transmission
25 assets or ownership interests j-n jointly-owned assets to
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better alj-gn asset ownershj-p with l-oad service and
operational needs as well as establish transmj-ssion servj-ce
purchase rights under PacifiCorp's and Idaho Power's
(colIectively, the "Parties" or singuJ-ar1y, the "Party")
respective OATTs. The transaction does not create any new
available transmission capacity. The ongoing maintenance
and ownership obligations are established in a single
agreement going forward, the Joint Ownershj-p and Operating
Agreement (*JOOA").
O. Pl-ease describe the need for the new
arrangements.
A.PacifiCorp and Idaho Power operate and
maintain respective ownership of certain jointly-owned
facilities as well as independently-owned transmissj-on
facilities in Idaho, Oregon, Washington, and Wyoming. The
operatj-on and ownership of many of these facilities is
governed under a compli-cated collection of legacy
agreements ("Legacy Agreements"), including a 1969 Jim
Bridger Ownership Agreement titl-ed the Restated
Transmj-ssion Service Agreement (*RTSA") and a 7969 Jim
Bridger Operation Agreement titled the Restated and Amended
Transmission Facilities Agreement (*RATEA"). Some of the
Legacy Agreements have been in place for over 40 years. In
the years fol-l-owing the establishment of such Legacy
Agreements, changes have occurred for both PacifiCorp and
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Idaho Power rendering the Legacy Agreements ineffective and
ill--suited over time to opti-mize existing transmission
facilities and effectively respond to regulatory changes,
Ioad growth, investment in system upgrades, and reliability
and operational needs. The complexity of these Legacy
Agreements has resulted in disputes over the years between
the Parties regarding contract interpretation. In
addition, the transmission systems of both Parties continue
to evol-ve and there is no effective mechani-sm under the
Legacy Agreements to account for evolving operational
procedures and changes in regulatory requirements. By
better aligning resources and establishing more modernized
agreements to govern ownership and the operation and
maj-ntenance of the associated transmissj-on facil-ities going
forward, this transaction benefits both Parties and puts
them in a position to better provide reliabl-e and efficient
transmission service for customers now and into the future.
The Parties intend to terminate or amend the Legacy
Agreements upon closing of the transaction.l
'The RATFA, RTSA, and lnterconnection and Transmission Service
Agreement (*ITSA") are the primary agreements between the parties.
There are a number of rel-ated agreements which support or are directly
connected to the RATEA, RTSA, and ITSA. The RATFA, RTSA, ITSA, and
remaining agreements are col-l-ectively referred to as the "LegacyAgreements." A complete list of the Legacy Agreements that wil-l- bereplaced, amended, or consol-idated by the proposed transaction are
identified in Schedules 1.1(S) and 1.1(h) to the JPSA.
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facilities
A.
Please summarize PacifiCorp' s transmj-ssion
and rights before the transaction.
Under the Legacy Agreements, PacifiCorp's
transmission facilities and ownership interests and rights
are located in three main areas: (1) transmission
facil-itles connected out of the Jim Bridger power plant
("Jim Bridger P1ant") in Wyoming, (2) transmission
facil-ities extending west of the Kinport substation and
Borah substation in Idaho to the Midpoint substation in
Idaho ("West of Kinport"), and (3) transmission facil-ities
north of the Goshen, Idaho, area. Please see Exhibit No. 1
for maps showing PacifiCorp's rights and assets before and
after the transaction.
V. RELIABILITY AI{D OPERAIIONAT BENEFITS
OF THE TRANSACTION
A. Jim Bridger Area
O. What is PacifiCorp's transmission current
ownership in the Jim Bridger area?
A.There are three 345 kilovolt ("kV")
transmission l-ines heading west and two 230 kV transmission
Iines heading south out of the Jim Bridger Plant. The
three 345 kV lines consist of: (1) the Jim Brj-dger Three
Mil-e Knol-I - Goshen l-ine; (2) the Jim Bridger Populus
Borah line; and (3) the Jim Bridger Populus Kinport
l-ine. Under the Legacy Agreements, PacifiCorp has 100
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percent ownership of two of the three transmlssion 1ines,
the Jim Bridger - Populus Borah transmission l-ine and the
Jim Bridger Populus - Kinport transmission l-ine, and
Idaho Power has 100 percent ownership of the remaining
transmissj-on lj-ne, the Jim Bridger - Three MiIe Knol-l
Goshen transmission 1ine. There are two 230 kV
transmission lines that are jointJ-y owned by the Parties.
O. What will PacifiCorp's transmissi-on ownership
in the Jim Bridger area be after the transaction?
A.Under the JPSA, PacifiCorp will obtain
approximately two-thirds ownership of all three of the 345
kV transmissi-on l-ines and Idaho Power will obtain
approximately one-third ownership of al-l three transmission
l-ines. In addition, PacifiCorp wil-l- obtain 100 percent
ownership of the two 230 kV transmission lines that connect
the Jim Bridger Pl-ant to the area of Point of Rocks,
Wyomi-ng, and Rock Springs, Wyoming.
o.Please describe the benefits associated with
the transaction in the Jim Bridger area.
A.There is a gap in ownership and capacity
available to PacifiCorp on the Jim Bridger - Three Mil-e
KnoII Goshen transmission line owned by Idaho Power,
limiting PacifiCorp's ability to reliably and cost-
effectively respond to Goshen area customer load
requirements during certain outage scenarios. For example,
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during a Goshen Kinport line outage or a Bridger - Goshen
line outage, PacifiCorp was limited in its ability to
respond in a timely manner, and dependent upon ldaho Power
being able to post capacity on its Bridger - Three Mil-e
Kno1l Goshen transmission line, which subjected
PacifiCorp to additional- costs. Following the transaction,
PacifiCorp will have an ownership percentage j-n all three
transmission l-j-nes, which will enable PacifiCorp to use its
own rights on all three transmission lines to serve
affected load and respond more effectively under certain
outage conditions. This improved ownership and access to
capacity going forward will also enable PacifiCorp to
facilitate long-term efficient operations and more cost-
effective load service. Lastly, the new arrangement will-
result in no change to PacifiCorp's ability to deliver Jim
Bridger Pl-ant generation to its customers using a
combination of transmlssion assets owned by Pacifj-Corp,
Idaho Power, and Bonneville Power Administration. With
ownership of both the 230 kV Ij-nes, Pacj-flCorp will- post an
additional- 200 MW of capacity avail-abl-e for transmission
customers to purchase.
B. Itest of [!3g!@
O.What are PacifiCorp's transmission ownership
theand rights in the west of Kinport area prior to
transaction?
VAIL, DIPacifiCorp 10
1 A. Idaho Power owns 100 percent of the three 345
2 kV l-ines, including one transmissj-on line that extends from
3 Kinport, Idaho, to Midpoint, Idaho, and two transmission
4 lines that extend from Borah, Idaho, to Midpoi-nt, Idaho.
5 Under the Legacy Agreements, PacifiCorp is al-Iowed 1,600 MVi
6 of transmission service across the transmission lines, of
7 which up to 200 MW could be dynamically scheduled.
I Q. What will PacifiCorp's transmission ownership
9 and rights in the west of Kinport area be after the
10 transaction?
11 A. As detailed in the JPSA, PacifiCorp will have
72 ownership rights and wheeling rights that it can use across
13 all three transmission 1ines. Specifically, PacifiCorp
14 will have 1,090 MW of ownership rights, plus 510 MW of firm
15 OATT service, including 400 MW of dynamic service.
76 PacifiCorp will be able to use a combination of point-to-
L7 point transmission service rights over ldaho Power's
18 system, and PacifiCorp network transmission service on
19 newly owned assets, providing operational flexibility not
20 afforded under the Legacy Agreements.
21 0. Please describe the benefits associated with
22 the transaction in the west of Kinport area.
23 A. Ownership rights enable PacifiCorp to provide
24 expanded, long-term system flexibility and economic service
25 to customers. Not being limited operationally by the terms
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of the Legacy Agreements al-so provides more flexibility for
PacifiCorp to optimize this capacity when needed for load
service, reliability, or as excess capaci-ty that can be
sold to third parties when not needed. In addition, 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. Benefits associated with the 1090
MW of ownership and 510 MW of firm capacity rights are
discussed in more detail in the testimony of Mr. Duvall.
C. North of Goshen Area
O.What are PacifiCorp's transmission ownership
prior to theand rights north of the Goshen area
transaction?
A. PacifiCorp leases transmission capacity from
Idaho Power on one 167 kV transmission line between the
Goshen, Idaho; Jefferson, Idaho; and Big Grassy, Idaho;
substations.
o.What will PacifiCorp's transmission ownershJ-p
and rights in the Goshen area be after the transaction?
A. Following the transaction, PacifiCorp will
have 62 percent ownership under the JOOA in this
transmission 1ine.
O. What transmission assets wiII be transferred
from PacifiCorp to Idaho Power in this transaction?
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A. PacifiCorp will transfer ownership of several
assets to Idaho Power through this transactj-on. Idaho
Power wil-I acquj-re an ownership interest in the Summer Lake
to Hemingway and Hemingway to Midpoint transmission l-ines.
As mentioned above, Idaho Power will also acquire one-third
ownershj-p of the Bridger Populus Borah l-ine and
Bridger Populus Kinport l-ine. In addition, Idaho Power
will- obtain an ownership interest in the Goshen Kinport,
and Hurricane - Walla Walla lines and a porti-on of the
Goshen - Antelope and American Fal-l-s - Mal-ad transmission
Iines currently owned by PacifiCorp.
O.Please describe the benefits associated with
the transaction in the Goshen area.
A.PacifiCorp and Idaho Power will jointly share
the costs to upgrade the existing 161 kV transmission line
between the Goshen and Jefferson substations as part of
this transaction. In addition, PacifiCorp's new ownership
in these transmission lines will- provide the ability to
continue to reliably serve existing and growing load served
from the Jefferson, Idaho, and Big Grassy, Idaho,
substations.
O.Please describe any other benefits resulting
from the transaction.
A. In addition to the benefits described above
related to specific changes in ownership and increased
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capacity, the transaction provides additional benefits to
PacifiCorp and its customers due to the increased
transparency, reliabiJ-ity, and fl-exibility provided by the
JOOA, enabling more efficient and reliable load service for
customers whil-e reducing risk during certain outage
scenarios. Specifically, the following summarizes further
benefits of the transaction:
o Exhibit No. 8 provides PacifiCorp's financial
analysis of the transaction, which demonstrates a neutral
rate impact to customers over a ten-year period (2015-
2024) . The val-ue of the assets being exchanged between the
Parties is nearly equalr ds detailed in Exhibit No. 9 and
the Partj-es' Application. Ongoing expenses fol-lowing the
closing of the transaction will be simil-ar to expenses
incurred today.2 PacifiCorp has the bona fide intent and
financial ability to operate and maintain the new assets
acquired by the transaction in the public service.
The new agreements meet current regulatory
requirements. Modernization of the agreements, including
firm transmission service provided under each Party's OATT,
wilI provi-de the ability to effectively and efficiently
operate and ensure consistency with evolving reliability
standards. Similar joint ownershj-p and operation and
' The effect of the
expenses is discussed in
proposed transaction on the Company's wheeling
more detail- in the testimony of Mr. Duval-l-.
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maintenance agreements have been accepted by the Eederal
Energy Regulatory Commission (*FERC") as meeting regulatory
requirements (i.e., EERC Docket ER10-1217, Populus Joint
Ownership and Operating Agreement) .
Future cost sharing opportunities. The JOOA
allows for cost sharing for future upgrades on jointly-
owned transmission facilities resulting in a strong
foundation for future needs between the Parties based on
mutual interest or need, including the potential
participation in future joint projects, thereby reducing
overall project costs to customers.
o Elimination of complex, outdated Legacy
Agreements that may not a11ow for the Parties to
effectively meet current regulatory requirements. The new
agreements are transparent and consistent with transmission
service under the OATT.
vr. cLosrt{G
O. Does this conclude your direct testimony?
A. Yes.
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AEEESEATION OE
)
EESTIMONY
IK
STATE OE OTE<,o.
\ cc
County ot Wltnatrr"W
T., Richard A. Vail, having been duly sworn to
testify truthfully, and based upon my personal knowledge,
state the following:
I am employed by PacifiCorp as the Vi-ce Presiclent. of
Transmission and am competent to be a witness in th:-s
proceeding.
f declare under penalty of perjury of the laws of
the state of ldaho that the foregoing pre-filed testimony
and exhibits are true and correct to the best of my
information and belief.
DATED this \{day of December 2A14.
SUBSCRIBED
December 2014.
AND SWORN to before me this day of
@
MYCOMMI
OTFICIAL SEAL
1-: irdtlFlcr,,ll l.tERRlNG
f,C'IARY FUflLIC.oqEGON
C0idtvllssl0N IJO. 4581 54
Ssl0t'i EXPIAE3 f,.AY 17, 2015 vAfL, DIPacifiCorp
Richard A. Vail
Notary f or: ()(e,to<l
Residing 'at:
exprres:My commission
16
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-14-41
GASE NO. PAC-E-14-11
VAIL, DI
TESTIMONY
EXHIBIT NO.6
WASHINGTON
#er l*%
CALIFORNIA N EVADA
ffi Pacific Power service area
I Rocky Mounain Power
service area
O Coal facilities
a Natural gas facilities
a Geothermal and other
I Hydro systems
A Wind facilities
O Coal mines
Pacifi Corp-owned primary
transmission lines
Transmission access
IDAHO
COLORADO
NEW MEXICO
E)fiibit No.6
Case No. IPC-E-14.i1
Case No. PAC-E-1+11
R. Vail, PAC
Page 1 of 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-14-41
GASE NO. PAC-E-14-11
VAIL, DI
TEST!MONY
EXHIBIT NO.7
Exhibit No.7
Case No.IPGE-1H1
Case No. PAC-E-l+11
R. Vail, PAC
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BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
GASE NO. IPC-E-14-41
GASE NO. PAC-E-14-11
VAIL, DI
TESTIMONY
EXHIBIT NO.8
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Exhibit No. 8
Case No. IPC-E-14-41
Case No. PAC-E-14-11
R. Vail, PAC
Page 1 ol 2
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Sales (MW-Year)
Network Service
Other Serivces
Behind The Meter
Total Network Load
Point-to-Point
Total Firm Load
Short-Term Firm
Short-Term Non-Firm
Total Short-Term
TotalSales (MW-Year)
Revenue
Network Service
Other Serivces
Behind The Meter
Total Network Load
Point-to-Point
Total Firm Load
Short-Term Firm
Short-Term Non-Firm
Total Short-Term
Total Revenue
PAC
8,665
Other Total
111 8,776
952 9s2
2s9 259
8,555
3,474
1,322
743
9,987
4,L57
L2,O79
s08
3,165
3,674
L5,753
8s.00%
PAC
2L3,3_32
2,065
127
561
L4,144
536
3,727
273,332
84,053
32,548
18,293
689
2,754
t5.oo%
Other
2,733
23,438
6,377
4,362
18,506
100.00%
Total
216,065
23,438
6,377
245,880
1o2,345
348,225
15,689
91,980
297,385
12,545
78,t33
50,840
3,144
13,847
90,678
388,053
8s.00%
15,991
67,832
L5.OOYo
707,669
455,894
100.00%
24.62
Exhibit No. 8
Case No. IPC-E-1441
Case No. PAC-E-14-11
R. Vail, PAC
Page2 of 2
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-14-41
cAsE NO. PAC-E-14-11
VAIL, DI
TESTIMONY
EXHIBIT NO.9
No Additions PAC>IPC IPC>PAC Difference
Additions PAC>IPC IPC>PAC Differcnce
Transmission Lines
Transmission Substation
Cash
Total
Transmission Lines
Transmission Substation
Cash
Total
Total
32,306 18,885 13,421't1,312 24,380 (13,068)0 353 (353)ffi
0
1,115
532
1,409
(s32)
(2e3)
PAC>IPC IPC>PAC Difference
Transmission Lines
Transmission Substation
Cash
Total
32,306 19,416 12,88912,427 25,789 (13,361)472 0 472ffi
PacifiCorp Assets (No Adds) Lines Substations Total
Electric Plant in Service
Accumulated Depreciation
Net Plant
PacifiCom Assets (Adds)
60,106 '.t4,O43 74,149(27,800) (2,731) (30,531)32,306 1't,312 43,618
Substations Total
Electric Plant in Service
Accumulated Depreciation
Net Plant
FERC Act. 353
FERC Act. 354
FERC Act. 356
Average
Adj. Deprec. Rate
Remaining Life
ldaho PowerAssets No Adds
60,106 15,158 75,264(27,800) (2,731) (30,s31)32,306 12,427 M,733
1.760/o
1.53o/o
1.88o/o
1.71o/o 1.760/o
3.17o/o 2.15o/o32 47
Lines Substations Total
Electric Plant in Service
Accumulated Depreciation
Net Plant
ldaho Power Assets (Adds)
30,480 33,308 63,788(11,ses) (8,928) (20,523)18,885 24,380 43,265
Lines Substations Total
Electric Plant in Service
Accumulated Depreciation
Net Plant
Adj. Deprcc. Rate
Remaining Life
31,011 34,716 65,728(11,s95) (8,928) (20,523)19,416 25,789 45.205
2.72o/o 2.37%37 42
1,054 266 1,320(544) (609) (1,153)510 (343) 167:
1,010 264 1,274(525) (614) (1,13e)485 (350) 13s
Exhibit No. 9
Case No. IPC-E-14-41
Case No. PAC-E-14-11
R. Vail, PAC
Page 1 of 1