20160921Comments.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail :
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
RE:CE IVED
20 IS SEP 2 I PM I : 3 8
· ·. · -: ·~'.~L \C , , -~. -cot1;,.,1ss10N
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION TO APPROVE AN)
AGREEMENT FOR ELECTRIC SERVICE )
WITH THE UNITED STATES DEPARTMENT )
OF ENERGY. ) ___________________ )
CASE NO. IPC-E-16-18
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Daphne Huang, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 33579 on August 31, 2016, in
Case No. IPC-E-16-18, submits the following comments.
BACKGROUND
On August 15, 2016, Idaho Power Company filed an Application seeking approval of a
new special services agreement with the United States Department of Energy (DOE) for service
at the Idaho National Laboratory (INL). The current agreement (2011 Agreement), approved in
Order No . 32354, was set to expire on September 14, 2016. The new agreement (2016
Agreement) was set to become effective on September 15, 2016. However, the Company
requested and was granted an extension of the expiring agreement until the new agreement is
approved. Order No. 33579.
STAFF COMMENTS SEPTEMBER 21 , 2016
STAFF ANALYSIS
The 2011 Agreement currently in place set forth the terms of agreement for electrical
service to the DOE's INL location. The 2011 Agreement specifies a 5-year agreement for the
Company to provide up to 55,000 kW monthly for the operation of the facilities. The service
includes three-phase, 60Hz alternating current at normal 138,000 volts with a maximum steady
state variation of plus or minus five percent under normal system conditions. The 2011
Agreement further outlines how the DOE will be billed for the maintenance of DOE-owned
equipment, given that the special contract customer under Schedule 20 is not subject to the
Monthly Facilities Charge Rate under Rule M.
The proposed 2016 Agreement is essentially the same as the 2011 Agreement, with the
primary change being a negotiated, but not executed agreement to transfer title of the DOE­
owned Antelope substation equipment to Idaho Power and PacifiCorp. However, since the
potential asset transfer has not been executed, Staff will wait to review the transfer of DOE­
owned Antelope substation equipment, if and when it takes place. That aside, the following
changes have been made to the contract:
• Updated estimates for the annual energy and demand usage, as well as an updated
estimate of the total annual service cost.
• Removal of a redundant term of authorization section.
• Restructuring of contract sections.
• Updated termination section with increased charge for early termination.
Beyond these changes, the terms set forth in the 2016 Agreement remain consistent with
the Commission-approved 2011 Agreement. Staff observes that previous agreements and the
proposed 2016 Agreement require the Company to maintain equipment owned by another entity.
Staff believes that any liability that comes as a result of the Company maintaining and operating
equipment the Company does not own should be at the Company's risk and not be borne by
ratepayers. However, given this expectation, Staff believes the changes in the 2016 Agreement
are reasonable and recommends approval of the Application.
STAFF COMMENTS 2 SEPTEMBER 21, 2016
STAFF RECOMMENDATION
Staff has reviewed the Company's Application and has no concerns with the proposed
agreement, provided that any liability that comes from maintaining and operating non-Company
owned equipment is not borne by other ratepayers. Accordingly, Staff recommends approval of
the Application effective upon approval by the Commission.
r/[
Respectfully submitted this ·If ) ?' day of September 2016.
Technical Staff: Johanna Bell
Mark Rogers
i :umisc:comments/ipce 16. I Sdjhjbmr comments
STAFF COMMENTS 3 SEPTEMBER 21, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2I5t DAY OF SEPTEMBER 2016,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF IN
CASE NO. IPC-E-16-18, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]
MICHAEL YOUNGBLOOD
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
~~~ SEC ARY
CERTIFICATE OF SERVICE