20180705Comments - Redacted.pdf

SEffi*o
An IDACORP Company
ON
July 5, 2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-18-08
ldaho Department of Administration's Petition for Exemption from the ldaho
Public Utilities Commission Master-Metering Standards - ldaho Power
Company's Comments
Dear Ms. Hanian
Enclosed forfiling in the above matter are an original and seven (7) copies of ldaho
Power Company's Comments.
Also enclosed are an original and seven (7) copies of the confidential portions of
Attachments 2 and 3 to the Comments. Please handle the confidential information in
accordance with the Protective Agreement executed in this matter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
LISA D. NORDSTROM
Lead Counsel
[e-mail]
LDN:kkt
RTC E IVE D
t$i3 jiil -5 Pll 3: l5
Lisa D. Nordstrom
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SSI
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n ord strom @ ida h opower. co m
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Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF THE PETITION OF
THE IDAHO DEPARTMENT OF
ADMINISTRATION FOR AN
EXEMPTION FROM THE IDAHO PUBLIC
UTILITIES COMMISSION'S MASTER-
METER!NG RULES FOR ELECTRIC
UTILITIES AND THE IDAHO POWER
MASTER-METER! NG STAN DARDS
)
)
)
)
)
)
)
)
)
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CASE NO. IPC-E-18-08
COMMENTS OF IDAHO POWER
COMPANY
On April, 13,2018, the ldaho Department of Administration ("lDOA') filed a petition
("Petition") with the ldaho Public Utilities Commission ("Commission") seeking an
exemption from the Commission's Master-Metering Rules for Electric Utilitiesl ("Master-
Metering Rules") and waiver of ldaho Power Company's ("ldaho Power" or "Company")
1 Master-Metering Rules for Electric Utilities, IDAPA 31.26.01
COMMENTS OF IDAHO POWER COMPANY - 1
Master Metering Standard2 (collectively referred to as "Rules") requiring that ldaho Power
individually meter the tenants of the State of ldaho's recently-acquired Chinden Campus
located at 11311 West Chinden Boulevard in Boise, ldaho ("Campus"). ln these
comments, ldaho Power recommends the Commission deny the proposed exemption.
ldaho Power believes that requiring individual meters in compliance with current
Commission-approved Master-Metering Rules will better achieve the goals of promoting
energy efficiency through more accurate price signals, billing accuracy, and a direct
customer-utility relationship. However, the Company recognizes the Commission must
consider the unique circumstances presented in this case to determine if such
circumstances warrant an exemption from those rules. ln its comments, the Company
sets forth information it believes relevant to the Commission's decision.
I. BACKGROUND
ln November 2017, the IDOA contacted ldaho Power to request electric service at
the Campus and to inquire about the possibility of ldaho Power assuming ownership and
providing ongoing maintenance of the electrical distribution system located at the
Campus, pursuant to Rule M of ldaho Power's tariff. At that time, ldaho Power informed
the IDOA of the Commission's Master-Metering Rules and discussed ldaho Power's
recommendation of requiring individual metering at each individual customer's building to
comply with the Rules.
During several subsequent discussions between November2017 and March 2018,
representatives from ldaho Power and the IDOA discussed those requirements further,
2 l.P.U.C. No. 29, Tariff No. 101, Rule E (Master Metering Standards)
COMMENTS OF IDAHO POWER COMPANY - 2
with the IDOA ultimately inquiring of ldaho Power about the possibility of pursuing an
exemption from the requirements of the Master-Metering Rules.
The Commission's Master-Metering Rule 1033 requires units of commercial
buildings to be individually metered where tenants control their own electric space
heating, water heating, or air-conditioning appliances. lt states:
103. MASTER.METERING AND INDIVIDUAL METERING IN
COMMERCIAL BUILDINGS AND SHOPPING CENTERS
(Rule 103).
No unit of commercial buildings and shopping centers shall be
master-metered for blectric service after July 1, 1980, if the
units for their tenants contain an electric space heating, water
heating, or air-conditioning (space cooling) unit that is not
centrally controlled and over which the unit's tenants
individually control electric usage. Tenants in otherwise
master-metered buildings whose electric load or who operate
appliances whose electric load exceeds the individual
metering threshold found in the utility's tariffs must be
individually metered.
ldaho Power's Master Metering Standard tariff found in Section 4 of Rule E is
nearly identical to Rule 103. Rule C of ldaho Power's tariff also limits the ability of
customers to resell electricity in master-metered configurations "unless the Commission
authorizes alternative procedures."a
ldaho Power met with Commission Staff ("Staff') on March 27, 2018, to inform
Staff of discussions between the IDOA and ldaho Power related to the Rules, and discuss
ldaho Power's interpretation of the Rules. ln a subsequent meeting between Staff, the
IDOA, and ldaho Power on April 5,2018, ldaho Power discussed its recommendation to
individually meter the buildings for purposes of supplying electric service to the Campus.
3 Master-Metering Rules for Electric Utilities, Rule 103, IDAPA 31 .26.01 .103.
4 l.P.U.C. No. 29, Tariff No. 101, Rule C (Service and Limitations), Section 6.
COMMENTS OF IDAHO POWER COMPANY - 3
On April 13,2018, the IDOA filed its Petition with the Commission seeking authority for
an exemption from the Master-Metering Rules and Rule E of ldaho Power's tariff.
II. MASTER.METERING RULES FOR ELECTRIC UTILITIES
The Public Utility Regulatory Policies Act of 1978 ('PURPA" or "Act") required the
Commission to consider whether it would adopt federal standards contained in the Act
with regard to master metering of electric service in new multi-occupant buildings. Section
133(b)(1) of the Act provided that master metering in new buildings "shall be prohibited
or restricted to the extent necessary to carry out the purpose of the Act." Section 1 15(d)
of the Act determined separate metering to be appropriate in new multi-occupant
buildings in which the occupant of each unit has control over a portion of the electric
energy used in the unit if the long-run benefits to the electric customers in the building
exceed the costs of purchasing and installing separate meters.
ln response to the requirements of PURPA, in 1980 the Commission opened a
docket to establish rules related to the allowance or disallowance of master metering.5 ln
addition to the conservation goals of PURPA, the Commission based its decision to adopt
the proposed master metering rules upon several premises:o
1. lndividually metered tenants who are responsible for paying their own electric
bills use less and waste less electric energy than master-metered tenants who
are not;
5 Re Master Metering Sfandards, Case No. P-300-15, Order No. 15556, 37 PUR 4th 1 19 (May 21,
1 980)
6 ld. at 120-121
COMMENTS OF IDAHO POWER COMPANY - 4
2. The ultimate consumers of electric energy are better served by a direct
customer relationship with the utility than by disguising utility costs in the rent
or by the landlord playing the role of the public utility;
3. lt is inequitable for electric customers to pay more or less than the cost of
electricity which they consume themselves.
Related to commercial buildings, the Commission established the master metering
requirements now known as Master-Metering Rule 103.7
III. CAMPUS ELECTRICAL SERVICE
HP, lnc. and its predecessor companies ("HP") initially developed the Campus
between 1976 and 1995. Through most of its history, the Campus was occupied solely
by HP and ldaho Power provided service in accordance with Schedule 19; as a primary
service level customer, HP was responsible for providing the transformation of power to
the voltage at which it would be used.8 The initial Point of Deliverye ("POD") was
established adjacent to ldaho Power's Hewlett Packard ("HPKD') substation located on
the west side of the Campus. ldaho Power metered all of HP's usage through a single
primary meter and HP owned, operated, and maintained all distribution equipment on its
side of the POD, which included a significant amount of electrical infrastructure
throughout the Campus that networks eight main buildings, two chillers, two boilers, and
several outbuildings.
7 lnitially identified in Order No. 15556's Appendix A as Rule 4(a), the Commercial building
requirements were ultimately promulgated as Master-Metering Rule 103. (IDAPA 31.26.01.103).
8l.P.U.C No. 29, Tariff 101, Rule B (Definitions) provides that "Primary Service is service taken at
'12.5 kilovolts (kV) to 34.5 kV. Customers taking Primary Service are responsible for providing the
transformation of power to the voltage at which it is to be used by the Customer."
e Rule B defines Point of Delivery as "the junction point between the facilities owned by the
Company and the facilities owned by the Customer; OR the Point at which the Company's lines first become
adjacent to the Customer's property; OR as otherwise specified in the Company's tariff."
COMMENTS OF IDAHO POWER COMPANY - 5
ln 2015, HP contacted ldaho Power regarding options to serve a tenant, Sykes
Enterprises ("Sykes"), that was unaffiliated with HP. ldaho Power informed HP of the
Rules and the Company subsequently installed a second primary metering package to
serve Building 8, which was being leased to Sykes. The Company's POD for that service
was the same location as the existing POD; ldaho Power installed the necessary metering
equipment at the POD and HP installed and maintained the distribution equipment
beyond that POD necessary to provide service to Sykes. !n accordance with section 5 of
Rule C of ldaho Power's tariff, the service provided to Building 8 is not interconnected
electrically to any other building on the premises.
Today, ldaho Power continues to provide primary service to the Campus through
the two above-described primary meters, with each POD located at ldaho Power's HPKD
substation next to the Campus on Cloverdale Road. Buildings 1,2,3,4, 5, 6, and 7 and
associated chiller units are served by the original primary meter and Building 8 is served
by a second primary meter. The buildings are also served by a complex network of
heating and cooling facilities. Please see Attachment 1 tor a map of the Campus and its
current tenants.
Through its discussions with the IDOA, and review of information provided to the
Commission in IDOA's Petition, the Company is now aware that there are currently
several entities leasing space at the Campus. All entities leasing space at the Campus
currently pay for their electric service through their commercial leases rather than directly
paying ldaho Power. The Company does not have the detailed energy usage information
by individual lessee (other than Sykes, for which it has the separate meter) that would be
necessary to fully evaluate the applicability of Master-Metering Rule 103, but understands
that the tenants have individual control of at least a portion of their energy use.
COMMENTS OF IDAHO POWER COMPANY - 6
IV. CONSTRUCTION STUDIES COST ESTIMATES
ldaho Power does not currently own or maintain any electrical facilities or metering
equipment beyond the PODs located near the HPKD substation. The IDOA has requested
cost estimates associated with ldaho Power owning, operating, and maintaining allfacilities
located on the Campus necessary to provide service to the Campus. Because the types of
facilities required and ultimate funding mechanisms would differ depending on whether the
Commission grants the exemption from the Rules, ldaho Power performed two construction
studies to determine what would be necessary for ldaho Power to perform such a role under
either scenario. Please refer to the construction studies included as Attachments 2 (Version
1) and 3 (Version 2).10
A. Version I (assumes master metering exemption is granted).
This version locates the POD adjacent to the HPKD Substation, and provides the
necessary configuration if the Commission grants the IDOA's request for an exemption to
the Rules. ln this version, ldaho Power and the IDOA would enter an arrangement under
ldaho Power's Rule M,11 Facilities Charge Service, which governs the provision of services
to customers who request that the Company design, install, own, and operate transformers
and other facilities located beyond the POD that are solely provided to meet the customer's
service requirements. The IDOA would not be responsible for an upfront Contribution in Aid
10 Portions of these construction studies are exempt from disclosure under tdaho Code $ 74-
105(4)(b) because they concern critical infrastructure, the public disclosure of which would jeopardize the
safety of persons, property, or the public safety.
11 l.P.U.C No. 29, Tariff No. 101, Rule M (Facilities Charge Service) is a voluntary service provided
at the customer's request and at the option of the Company.
COMMENTS OF IDAHO POWER COMPANY - 7
of Construction ("CIAC"), rather it would pay an ongoing monthly facilities charge.12 ln this
version, ldaho Powerestimated the IDOA's monthlyfacilities charge paymentto be $20,191.
As described in greaterdetail in Section 8 of Attachment 2, this amount includes an estimate
for ldaho Power to (1) install new equipment pursuant to Rule M (estimated installation cost
of $1,311,508), and (2) assume ownership of certain existing facilities located at the
Campus.
While ldaho Power does not have a standard option to assume ownership of
customer-owned equipment and provide ongoing maintenance, at the request of the IDOA,
ldaho Power explored what, if any, of the existing facilities ldaho Power could reasonably
and safely own, operate, and maintain going forward. After ldaho Power conducted an
extensive on-site evaluation of facilities located beyond the POD currently owned, operated,
and maintained bythe IDOA, the Company concluded thatthe bulk of the distribution system
located at the Campus is non-standard to ldaho Power's distribution system and acquiring
the IDOA's equipment would pose operational concerns for ldaho Power.l3 While ldaho
Power cannot reasonably accommodate the transfer of ownership of most of the equipment
on-site, it believes it can safely own, operate, and maintain the existing primary conductor
serving the Campus. lf the Commission were to grant an exemption to the Rules, and the
IDOA were to request that ldaho Power provide Rule M, Facilities Charge Service, ldaho
Power proposes valuing the cable based on an estimated replacement cost (to be finalized
12 Under ldaho Power's Schedule 66, Miscellaneous Charges, monthly charges for Rule M facilities
are determined by multiplying the monthly facilities charge rate by the Company's total investment in
distribution facilities installed beyond the POD. The monthly rate depends on the rate schedule the
customer takes service under, as well as the age of the facilities. For commercial customers taking primary
levelservice under Rate Schedules 9 and 19, facilities installed 31 years or less are charged 1.41 percent
per month and for facilities installed for more than 31 years the monthly rate is 0.59 percent.
13 Reference Section 3 of Attachment 2 for additional details.
COMMENTS OF IDAHO POWER COMPANY - 8
at the time of transfer), and assessing a Schedule 66 facilities charge monthly rate of 0.59
percent because the majority of the cable is believed to be over 31 years old. The Company
believes, given the unique circumstances in this case, this is a reasonable and economic
alternative to asking the IDOA to remove the existing cable and requiring the IDOA to fund
the installation of new facilities installed by ldaho Power.
B. Version 2 (No exemption required/received; individual meter points at each
building).
This study, found in Attachment 3, locates the POD at each building and/or each
chiller at the Campus under a traditional metering arrangement where no master metering
occurs.la The configuration set forth in Version 2 anticipates ldaho Power separately
metering each building and chiller (11 primary meters plus a limited number of secondary
metersl5) on the Campus. ln this version, facilities necessary to provide service from the
HPKD substation to each POD would be installed in accordance with Rule H,16 and for
facilities beyond the 11 primary meters, the State would enter into a Rule M facilities
charge arrangement.
The IDOA would be required to contribute an upfront CIAC for the Rule H related
work (estimated at $891,081) and the remainder of necessary facilities (estimated at
$837,741) would be installed pursuant to Rule M, with ldaho Power recovering the costs
through an ongoing monthly facilities charge (estimated at $11,812lmonth). This version
also assumes the Company would take ownership of the conductor more fully described
la Version 2 envisions a single tenant in each building. lf multiple tenants occupy a building with a
single meter, theoretically master metering could still exist, albeit on a small scale.
ls Version 2 includes secondary meters under Schedule 95 for peripheral services such as a fire
suppression pump, parking lighting, and irrigation service to maintain Campus operations.
16 |.P.U.C. No.29, Tariff No. 101, Rule H (New Service Attachments and Distribution Line
lnstallations or Alterations) applies to requests for electric service...that require the installation, alteration,
relocation, removal, or attachment of Company-owned distribution facilities.
COMMENTS OF IDAHO POWER COMPANY - 9
17 IDOA Petition at 10.
18 Order No. 15556, 37 PUR 4th,119,121
COMMENTS OF IDAHO POWER COMPANY - 1O
above, but because the conductor would be located prior to the PODs, it would not impact
the IDOA's facilities charge.
The total construction cost estimate for Version 2 ($t ,728,822) is $417 ,314 higher
than the estimate for Version 1 ($t,31 1 ,508). The primary difference between the two
versions is attributed to the expanded scope of work stemming from the installation of
individual meters described more fully in Section 8.4 of Attachment 3.
IV. OTHER CONSIDERATIONS
While ldaho Power has no operational preference between the two Campus
configurations envisioned in the construction studies, ldaho Power continues to believe
the individual metering configuration of Version 2 is optimalto achieve several regulatory
considerations. lndividual metering of each building allows for: (1) adherence to the
regulatory policies that underlie the Master-Metering Rules, (2) accurate billing, (3) tenant
flexibility, (4) consistent treatment among customers, and (5) a direct customer
relationship.
ln addition to these regulatory considerations, the Company also provides a
discussion related to the cost estimates from the construction studies, below.
A. Underlying Premise of Master Metering
As noted in the IDOA Petition,lT the Master-Metering Rules were developed to
promote energy efficiency by providing control of energy use to each occupant of a multi-
occupant facility. ln its Orderls establishing master metering rules, the Commission based
its decision to adopt the Rules on the three premises discussed previously: customer usage
behavior, direct customer relationships with the utility, and equitable charges for electricity.
ln this €se, the Company does not believe these premises can be upheld without individual
customers being individually metered.
B. Accuracy of Billing.
_ The existing Campus is billed on two separate Schedule 19 accounts, with usage
for Buildings 1-7 served at one meter and usage for Building 8 served at a second meter.
None of the lessees at the Campus currently are billed by ldaho Power. As the IDOA
states on page 5 of its Petition:
IDOA is responsible for utilities under all the assumed leases.
Campus Building 8, occupied by Sykes Enterprises,
lncorporated, is separately metered; however, the tenant is
not required to pay for electrical service by the assumed lease
unless its use exceeds a usage cap specified in the lease.
Under the Campus Building 8 lease, IDOA is also responsible
for supply of heating and air conditioning to the building
sufficient to maintain an indoor air temperature between 68
and 72 degrees.
ln its Petition, the IDOA cites provisions in the HP lease that require the IDOA to
separate the utilities serving the HP-leased premises from the remainder of the Campus.le
ln response to Staffs discovery requests, the IDOA provided a methodology for allocating
ldaho Power's monthly bill among the building/tenants associated with that bill using sub-
metering. The method proposed for allocating electric bills to HP appears to be based on
allocations of sub-metered kilowatt-hours ("kWh").20 The IDOA believes its proposed
method of bill allocation and use of sub-metering accurately reflect HP's use of electric
1s IDOA Petition at 7
20lDOA's Responses to Staff Production Request Nos. 4, 7, and 10 are included in Attachment4
to these Comments.
COMMENTS OF IDAHO POWER COMPANY - 11
service and result in a reasonable approximation of actual energy costs, as HP's use of the
Campus does not differ from other users in the type of activity or hours of use.21
When determining whether the proposed sub-billing would be accurate, the
Company believes it is important for the Commission to consider that Schedule 19 pricing
is not based entirely on the amount of kWh consumed. The Commission-approved rate
structure contained within Schedule 19P22 includes components that would not be possible
to accurately allocate underthe IDOA's proposed methodology. These components include
the Basic Charge, the Demand Charge, and the On-Peak Demand Charge. lf energy usage
patterns among the lessees are consistent, the allocation method may be a reasonable
approximation of individually-metered accounts. Nonetheless, the Company believes the
most accurate billing would result from individually metering each tenant (building).
It is also important for the Commission to consider that if individual meters are
required, the rate schedule under which each POD takes service would be subject to the
applicability rules in the Company's general service schedules. Based on historical usage
information provided to ldaho Power, all 11 of the primary accounts will either qualify for
service under Schedule 9P or Schedule 19P.23 Additionally, Version 2 of the Construction
Studies contemplates secondary metering billed under Schedule 95 would be necessary for
peripheral Campus operations.
21 IDOA's Responses to Staff Production Request Nos. 7 and 10 (Attachment 4).
22 Page 4 of |.P.U.C No. 29, Tariff No. 101, Schedule 19 (Large Power Service) containing the
Basic Charge, the Demand Charge, and the On-Peak Demand Charge is provided as Attachment 5 to
these Comments.
23 ldaho Power does not have the detailed historical energy usage information necessary to
determine with certainty which rate schedules the 11 primary meters contemplated in Version 2 of the
Construction Studies would qualify for.
COMMENTS OF IDAHO POWER COMPANY - 12
Billing each individual building at the appropriate rate structures will better align price
of electricity with the cost of service as compared to allowing the aggregated billing under a
single Schedule 19P POD. The Company has other instances of single customers taking
service at more than one POD at a premise, and requires those individual PODs to qualify
for the appropriate schedule. ln fact, the Company is precluded from aggregating meter
readings together for purposes of billing.2a ldaho Power does not have the detailed energy
usage information available to quantify the estimated impact of the billing under individual
meters when compared to a single meter bill.
Lastly, the Company believes it is important for the Commission to consider the
potential impacts of the IDOA's inability to accurately bill HP for their usage. On page 7 of
its Petition, the IDOA states:
HP lnc. has a very complex Supervisory Control and Data
Access (SCDA) system that meters and measures all utility use
at the HP lnc. leased premises. For business confidentiality
reasons, HP lnc. will not share the SCDA system or its
information with IDOA. HP Inc., however will use this
information in conjunction with its control of chill plant number 1
and boiler plant number 1, its BAS system controlof lighting and
HVAC, and as additional information in an audit of IDOA to
confirm its utility usage under its contractually required sub-
metering of its leased premises.
On page 9, the Petition goes on to state.
The HP lnc. lease does not allow the IDOA to pass through or
charge any costs related to electrical service other than the
actualcharges from ldaho Power Company related to HP !nc.'s
use of electricity. lf HP Inc. SCDA data does not match the
IDOA invoices and an HP !nc. audit finds that IDOA overstates
electric charges, the lease providesthat IDOA is required to pay
the audit cosfs, which could be subsfanfta/. (Emphasis added)
2a Section 5 of Rule C requires: "where separate Points of Delivery exist for supplying service to a
Customer at a single Premises or separate meters are maintained for measurement of service to a
Customer at a single Premises, the meter readings will not be combined or aggregated for any purpose
except for determining if the Customer's total power requirements exceed 20,000 kW.'
COMMENTS OF IDAHO POWER COMPANY. 13
The only way to ensure HP only receives actual charges associated with HP's use of
electricity is to individually meter and bill HP for its usage.
C. Tenant Flexibility
The IDOA's Petition states that the long-term plan for the Campus is for it to be
occupied entirely by the State of ldaho and "not operated as a commercial
"ctivity."2s
However, on page 6 of the Petition, the IDOA also indicates that "a key issue in the
Governor's and Legislature's decision to pursue a purchase of the Campus was retaining
HP lnc. as a part of the Treasure Valley business community" and explains the HP lease
has an initial lease term of seven years, with two renewal options each for a term of five
years, for a total of 17 years.
While the State's long-range plan is to fully occupy the Campus, and the IDOA
asserts it currently "has no authority to lease the Campus to any private entity outside of the
existing leases at the Campus,"26 these long-term plans could change over time with
changes in the economy, commercial office rental and vacancy rates, tenant lease renewal
decisions, and other factors. Separate metering would provide more flexibility in case the
State's plans change.
D. Potential Application to Other Customers
While facts differ from case to case, it is possible that providing one exemption to the
Master-Metering Rules may lead to additional requests for exemption from the Rules. ln
another commercial setting, owners made significant energy efficiency improvements or
modifications to the heating and cooling systems to remove individual tenant control, to
25 IDOA Petition at 6.
26lDOA Petition at 8.
COMMENTS OF IDAHO POWER COMPANY - 14
achieve the underlying goals of the Master-Metering Rules.27 The Commission has also
required significant energy conservation measures to be incorporated into the initial
construction of congregate residential living facilities.2s As set forth in the IDOA's discovery
responses to Staffls Production Request Nos. 8 and g found in Attachment 6, the IDOA
anticipates energy efficiency measures will be installed in Building 2; it does not anticipate
entering into an Energy Savings Performance Contract as described in ldaho Code S 67-
5711D. lf an exemption is permitted in this case, it is important that such exemption be
based on the narrow set of facts unique to this case.
E. Direct Customer Relationship
The direct customer relationship with the utility, described in Order No. 15556 as a
premise upon which the Commission decided to adopt Master-Metering Rules, would be
best achieved by individual metering of occupants. !n a direct customer relationship, ldaho
Power has additionaldata about customers' individualenergy use patterns, and can assist
the customer in identifying behaviors directly impacting their consumption and demand thus
enabling them to make wiser choices about their future energy usage.
The recording and management of hourly energy consumption data is the basis
for the Company's ability to provide customers with access to detailed data about their
27 ln the Matter of the Joint Application of ldaho Power Company and Sinclair Oil Corporation for
fhe Sa/e and Transfer of Ceftain Utility Owned Facilities, Case No. IPC-E-05-16, Order No. 29864 at 2. ("To
comply with the spirit of the master-metering rule, Sun Valley asserts that within 60 days of transfer, it will
retrofit the individual thermostats for each tenant so that each thermostat will be centrally controlled by Sun
Valley.")
28 ln the Matter of the Request of Crosslngs Corporation for an Exemption for the RiverPtace Senior
Living Community from Gas, Electric and Water Customer Relations Rule 9.2, IDAPA 31.C.9.2, Case No.
IPC-E-91-21, Order No. 23936. ln the Mafter of the Reguesf by the City of Boise for an Exemption from
the Commission's Master Metering Rule 102, IDAPA 31.26.01 102, Case No. GNR-E-94-1, Order No.
25401. ln the Mafter of the Reguesf of Orofino Retirement Properties, lnc. for an Exemption from Rule 102
of the Commlssion's Master-Metering Rulesfor Electric Utilities, Case No. \ M/P-E-96-5, Order No. 26512.
ln the Matter of the Reguesf of Crossrngs Corporation for an Exemption from Rule 1 02 of the Commissrbn's
Master-Metering Rules for Electric Utilities, Case No. IPC-E-96-7, Order No. 26451 .
COMMENTS OF IDAHO POWER COMPANY - 15
individual energy consumption, thus enabling them to make wiser choices about their
future energy usage. Daily and hourly usage data is typically validated and posted within
72 hours so that customers can use the available pre-bill information to reduce their bill
by proactively managing their energy consumption. This level of data empowers
customers to identify energy usage patterns and behaviors directly impacting their
consumption.
Buildings without individual meters will not have time-based usage history
available to resolve usage questions or concerns, or to allow the IDOA to evaluate rate
options like time-of-use or critical peak pricing in the future. Because Idaho Power
customer service employees utilize these same tools when assisting customers,
employees will not have access to detailed usage information to provide optimal
information to assist the IDOA with its usage and billing inquiries.
Further, in this mse, a direct relationship between Idaho Power and HP would appear
to address the IDOA's lease requirement that HP be billed its actual utility costs.
F. Cost Considerations.
1. lncremental Meterinq Costs:
ldaho Power's construction studies estimated thatthe overall increase in construction
costs for individually primary metering the Campus buildings versus modifying to use a
single primary meter is approximately $417,000. As the IDOA noted on page 5 of its Petition,
the leases assumed by the IDOA are expected to expire in the next two to four years, after
which the State will occupy the space. For this set of occupants, the long-run benefits of
COMMENTS OF IDAHO POWER COMPANY - 16
individually metered buildings-as articulated in PURPA Section 115(d)2e - are likely
minimal. With renewal options, HP's lease could continue for at least 17 years from
inception; the potential long-run benefits of individual metering would be more substantial.
As an additional point to consider, the incremental metering costs are potentially
mitigated by reductions in the costs the State would incur to implement their own SCADA or
sub-metering procedures on the Campus, as well as reductions in costs the State may be
subject to related to utility bill audit provisions in its HP lease.
2. Upfront costs versus onqoinq monthlv charqes:
Because the funding mechanisms are different under the two versions, it is
important to consider the impacts of the upfront CIAC required to be paid by the State, as
well as the ongoing monthly costs associated with each version, summarized in the
following table:
Upfront CIAC
(Rule H)
Ongoing Annua!30 Charge
(Rule M)
Version 1 $242,292
Version 2 $891,081 $141,744
lnstallation of facilities necessary to individually meter tenants would result in estimated
upfront costs to the State of $891,081 according to the Company's construction studies. But
the studies also indicate that facilities charges would be lower by approximately $100,548
per year under that scenario (assuming current rates). This lower facilities charge should
be taken into account when evaluating the overall financial impact of individually metering
2s ln its Order No. 15556 establishing the master metering rules, the Commission noted thatthe
difficulty of measuring the benefits of fostering and maintaining direct relations between electric utilities and
their customers and of equitable treatment of the ultimate consumers of electricity. Although it was
"confident that in most instances the rules which we propose could survive a strict cost-benefit analysis
focusing solely upon quantifiable benefits to the customer or to the utility, but we have phrased neither our
rules nor our order in these terms." 37 PUR 4th 1 19, pp. 120-121 .
30 Version 1 monthly facilities charge for first 31 years is estimated at $20,191/month; Version 2
monthly facilities charge for first 31 years is estimated at $1 1,812/month.
COMMENTS OF IDAHO POWER COMPANY - 17
the Campus, as over the long-run the reduced facilities charge could more than offset the
higher upfront costs to the State.
V. CONCLUSION
ldaho Power believes that its customers are best served and the intent of the
Master-Metering Rules is best met by limiting exemptions from the Rules. lndividual
metering allows for electricity charges to be based on actual use of the electrical system,
sends appropriate price signals to customers, and allows customers to respond to those
signals by employing energy efficiency or demand reduction measures. However, the
Company also recognizes that there are many other factors for the Commission to
consider in rendering its decision in this case.
Operationally, the Company is prepared to serve the Campus as desired by the
IDOA under either an individual or master-metered configuration. Should the
Commission authorize an exemption from the Rules, and the IDOA desire ldaho Power
to provided facilities services beyond the POD, the Company will charge for these
facilities charge services and take ownership of the existing conductor in the manner
described above in Version 1 of the Construction Studies unless the Commission order
directs otherwise. lf it denies the IDOA's Petition for a permanent exemption, the
Commission should evaluate granting the IDOA a temporary exemption from Master-
Metering Rule 103 and relevant portions of ldaho Power tariff Rules C and E to allow the
IDOA's current billing practices to continue until individual meters are installed as set forth
in Version 2 of the Construction Studies.
DATED at Boise, ldaho, this 5th day of July 2018.
!SA . NOR OM
COMMENTS OF IDAHO POWER COMPANY - 18
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the Sth day of July 2018 I served a true and correct
copy of COMMENTS OF IDAHO POWER COMPANY upon the following named parties
by the method indicated below, and addressed to the following:
ldaho Department of Administration _Hand Delivered
Julie K. Weaver X U.S. Mail
Deputy Attorney General _Overnight Mail
Contracts and Administrative Law Division _FAX
954 W. Jefferson, 2nd Floor X Email [e-mail]
Boise, ldaho 83720-0010
Commission Staff
Karl Klein
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
X Hand Delivered_ U.S. Mail
_ Overnight Mail_ FAXX Email [e-mail]
o
Ki , Executive Assistant
COMMENTS OF IDAHO POWER COMPANY - 19
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
GASE NO. IPC-E-1 8-08
IDAHO POWER COMPANY
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BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
GASE NO. IPC-E-I9-09
IDAHO POWER COMPANY
ATTAGHMENT 2
EIffi*o
An toAcoRP companY
Gonstruction Study
State of ldaho
Department of Admi n istration
Boise, ldaho
Version 1 - Point of Delivery at Hewlett Packard Substation
Final Report
June 22,2018
for
in
State of ldaho - Department of Administration Construction Study 2018
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 1
TeeLe oF CoNTENTS
Table of Contents
List of Tables
List of Appendices
1. Introduction
2. Background
3. Required Upgrades to the State's Chinden Campus Electrical System - Version 1 .....
3. l. Summary:..............
.2
.2
3.2. Rule M Facilities Charge Service Work Description:3
5
5
4. Construction Sequencing ...........
5. Regulation, Permiffing, and Other Requirements
6. Customer Requirements.................6
8. Project Funding - Rule M Cost Estimate for Monthly Facilities Charge 7
9. Estimated Schedule .............8
10. ConclusionA.,lext Steps 9
LIsT oF TABLES
Table I
Estimated Schedule .,............8
LIsT oF APPENDIcES
Appendix A: Rule M
Appendix B-1: Idaho Power Work Order Map of Substation and Campus
Appendix B-2: Idaho Power Work Order Map of Campus
Appendix C: Hewlett-Packard Site Power Distribution Drawing
Appendix D: 5136 Vault Specifications
June 22,2018State of ldaho - Department of Administration Construction Study Version 1
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1. lrurnooucnoN
The State of Idaho - Department of Administration ("State") requested Idaho Power Company
("ldaho Power" or "Company") evaluate the modifications necessary for Idaho Power to own and
operate the electrical system at the State's Chinden Campus (the "Project"), including the
following:
o What, if any, portion of the Chinden Campus' current electrical system meets Idaho
Power's standards;
o Requirements for redesigning the existing electrical distribution system to Idaho Power
construction standards;
o Requirements associated with various metering configurations;
o Estimated costs for design and construction of Idaho Power electrical distribution work;
o Estimated monthly amount of facilities charge service;and,
o Estimatedconstructiontimeline.
Idaho Power is providing two Construction Studies to the State. Version I locates the Point of
Delivery (POD) at the Hewlett Packard Substation, and provides the necessary configuration, if
the Idaho Public Utilities Commission ("Commission") grants the State's request for an exemption
to the Commission's master metering rules (Case No. IPC-E-18-08). Version 2 locates the POD
at each building or chiller at the Chinden Campus, and provides the necessary configuration if the
Commission does not grant the State's request in Case No. IPC-E-18-08.
This Construction Study outlines the preliminary estimated costs and timeline associated with
Version I and is dependent upon the Commission approving the State's request for an exemption
from the Commission's master metering rules in Case No. IPC-E- 18-08. This Construction Study
is not a binding offer, but rather a conceptual study completed by Idaho Power for purposes of
providing the State with information relevant to the State's decision to proceed with the Project.
2. BAcKGRoUND
In November 2017, the State inquired about Idaho Power assuming ownership and providing
ongoing maintenance of the electrical distribution system located at the State's Chinden Campus,
pursuant to Rule M of Idaho Power's Tariff. At that time, Idaho Power informed the State of the
Commission's Master Metering Rules for Electric Utilities (IDAPA 31.26.01) ("Rules") and
discussed Idaho Power's recommendation of requiring separate PODs at each individual
customer's building to comply with the such Rules.
Customers requesting load greater than I MW receive service at the primary voltage, and are
responsible for providing transformation of power to the necessary voltage for use by the customer
beyond the POD. Distribution facilities installed by Idaho Power, up to and including the meter
at the primary service level customer's POD, are installed pursuant to the terms of Rule H of Idaho
Power's Tariff (Rule H). Customers taking service at a primary voltage level may request that
Idaho Power own, operate, and maintain distribution facilities located beyond the POD pursuant
to Rule M.
June 22,2018State of ldaho - Department of Administration Construction Study Version 1
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 1
Customers requesting load less than I MW receive service at a secondary voltage, and all
distribution facilities installed prior to the POD (including transformation facilities) are installed
pursuant to Rule H.
The State inquired about an exemption from the Commission's Rules and requested Idaho Power
evaluate owning facilities beyond the POD if the Commission were to grant the State an
exemption.
While the Company does not currently have a standard option to assume ownership of customer-
owned equipment and provide ongoing maintenance in exchange for the customer paying a
facilities charge, Idaho Power evaluated the electrical distribution equipment at the Chinden
Campus and committed to explore options for accommodating the State's request. Ultimately, the
bulk of the distribution system located at the Chinden Campus is non-standard to Idaho Power's
distribution system and acquiring the State's equipment would pose operational concerns for Idaho
Power as further described below. However, the distribution cable and duct-vault system at the
Chinden Campus is currently constructed and maintained consistent with Idaho Power's operating
standards and practices. If the Commission grants the State's exemption request, Idaho Power is
willing to assume ownership of the cable in exchange for the State paying a facilities charge
(further described in sections 3.2 and 8). Accordingly, the remainder of this Construction Study
anticipates Idaho Power taking ownership and maintenance of the equipment standard to its
system.
3. ReoutRED UpcnaDES To THE STAIC'S C HINDEN CEUPUS
Euecrnrcal Svsreu - Venstoru 1
At the State's request, Idaho Power is providing a proposed electrical configuration appropriate
for Idaho Power to own and operate in accordance with Rule M of ldaho Power's Tariff. Rule M
is attached as Appendix A to this Construction Study for the State's reference.
3.1. Summary:
IIIII-IIII
I Idaho Power Troublemen are on call to provide emergency response
State of ldaho - Department of Administration Construction June 22,2018
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The existing transformers and switches at the State's Chinden Campus do not meet Idaho Power
standards and must be replaced for Idaho Power to provide facilities charge service. Idaho Power
does not operate or maintain equipment inside of buildings and is phasing out live-front
switchgear. The State's Chinden Campus distribution wiring is a delta system. The Idaho Power
distribution design standard is a grounded wye system with a system neutral. Idaho Power does
not use a delta distribution design system that does not contain a system neutral. Therefore, Idaho
Power does not retain inventory of delta primary voltage electrical equipment like the transformers
installed at the State's Chinden Campus. Idaho Power employees are trained to operate and
maintain a wye standard primary voltage system.
The existing primary cable at the Chinden Campus also does not meet Idaho Power's standards;
however, Idaho Power is able to take ownership and re-use the cable, where possible, considering
there are no operational differences between the existing cable and Idaho Power's standard cable.
In addition, the existing cable conduit is properly sized and can accommodate Idaho Power's
standard cable, which Idaho Power will use to replace the existing cable if failure occurs in the
future.
Idaho Power's proposed design (work order maps) for Version I are attached as Appendices B-1
and B-2 to this Construction Study for the State's reference.
3.2. Rule M Facilities Gharge Service Work Description:
Idaho Power obtained identifring information associated with the State's switches and
transformers, to be removed from the Chinden Campus, from the Hewlett Packard Site Power
Distribution Drawing No. E-5. Hewlett Packard Site Power Distribution Drawing No. E-5 is
attached as Appendix C to this Construction Study for the State's reference. New Idaho Power
devices will be renumbered by Idaho Power.
The following descriptions of work to be completed under a Rule M facilities charge arrangement
start with equipment located at the substation and move clockwise through the Chinden Campus
as shown on the ldaho Power work order maps (attached as Appendices B-l and B-2):
t
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4. GoIISTRUCTION SEQUENCING
Cutover to the new system requires multiple isolated outages. The outages will be planned and
coordinated with the State to minimize interruptions. The construction schedule will be adjusted
accordingly to meet the State's request that outages are scheduled at least six months in advance
to avoid interruption of service during the summer months and holidays.
5. ReculnnoN, PenmtrnNc,AND OTXEN REOUINEMENTS
The metering configuration must be consistent with the outcome of the State's petition for an
exemption from the Commission's Rules. If this exemption is not granted, this Version 1
Construction Study with a single POD at HPKD is not a viable option.
Idaho Power will work with the State to understand the permitting necessary for the Project and,
when applicable, jointly coordinate the necessary permit applications. It is also important the State
understand there may be additional regulations and permitting requirements applicable to the
State's facilities which are not ldaho Power's responsibility, and which could impact the estimated
cost and schedule. Although Idaho Power will work with the State on permitting, it is ultimately
the State's sole responsibility to understand and comply with all necessary regulations and permits.
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6. CUSToMER ReouInEMENTS
If the State proceeds with Version 1, and upon Commission approval of the State's request for an
exemption and Idaho Power entering into a facilities charge arrangement with the State, the State
will transfer ownership of the underground duct vault and cable to Idaho Power, at no cost to ldaho
Power, pursuant to an Asset Transfer Agreement to be negotiated between the State and Idaho
Power. The State will also be required to provide ldaho Power with the necessary easements on
the State's property to accommodate installation, operation, maintenance, alteration, relocation,
upgrades, conversation, and/or removal of the facilities and equipment associated with the Project,
at no cost to Idaho Power. The easements and executed Asset Transfer Agreement must be in
place prior to the Project construction start date, as shown in the estimated construction schedule
set forth in Section 8.
In addition, the State will be responsible for other requirements associated with the Project
including, but not limited to, the following:
Disposing the transformers and switches that are removed by Idaho Power;
Replacing damaged landscape and sidewalks;
Providing and installing service wire from the buildings to the secondary side of the
transformers;
Verifying to Idaho Power that the State's back-up generators are isolated from back-
feeding to the primary side of the transformers in accordance with applicable codes;
Providing necessary access for specialized equipment (cranes, line beds, cable pulling
equipment, etc.);
Allowing Idaho Power to provide a parallel Idaho Power lock, in addition to the State's
lock, on enclosures containing Idaho Power equipment; and,
Coordinating and communicating outage information with the State's Chinden Campus
tenants.
7. CouPLExrnES U ttxttowNs AN D Assutvt PTToNS
Idaho Power prepared the cost estimate associated with this Version I Construction Study in
accordance with the upgrades outlined in Section 3. The cost estimate is conceptual in nature and
does not represent a refined engineering design; as a result, the final configuration and costs may
change. Factors that may contribute to such changes in configuration and cost include, but are
not limited to:
r The estimates are based on ldaho Power's construction study estimating tools and not a
detailed design estimate;
o Contingencies have not been added and are commonly as high as 30Yo;
o Exact locations of meters and transformers have not been determined;
o ldaho Power will likely contract this work and, given the current economy, contractor bids
could escalate substantially;
State of ldaho - Department of Administration Construction Study Version 1 June 22,2018
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. Commodity markets have at various times exhibited significant price volatility which could
impact material and salvage values;
o Additional equipment to ensure the State's back-up generators are isolated from back-
feeding to the primary side of the transformers is not included;
. Adders to account for crews working non-standard hours to minimize impact of outages
on tenants are not included; and,
o Salvage value of removed cable has not been included - salvage value, if any, will be
determined at the time of cable removal and adjusted to cover removal costs.
8. PnotEcr Futtorttc - RuLe M Cosr ESnMATE FoR Mournly
FecrrnEs CHARGE
At the State's request, Idaho Power completed a facilities charge estimate in accordance with Rule
M whereby Idaho Power owns, operates and maintains distribution facilities located beyond the
POD in exchange for the State paying a monthly facilities charge. If Idaho Power and the State
enter into a Rule M arrangement, the State's estimated monthly facilities charge payment is
$20,191 . This includes an estimate for Idaho Power to ( 1) install new equipment pursuant to Rule
M and (2) assume ownership of certain existing facilities located at the Chinden Campus (the cable
described in Section 2).
1. New Equipment: Idaho Power estimates new equipment installation pursuant to Rule M
in the approximate amount of 51,311,508, which would result in a 518,492 monthly
payment (the facilities charge rate for all new equipment equals l.4lo of the initial
investment cost).
2. Existine Cable: If the Commission grants the State an exemption from its Rules, Idaho
Power proposes the monthly facilities charge be based on the replacement value of the
existing cable, currently estimated at$287,887. Also, because most of the existing cable
has been in service for over 3l years, Idaho Power also proposes assessing the facilities
charge rate of 0.59Yo against the value of the cable. Under this arrangement, the estimated
monthly payment for the existing cable would be $ 1,699. The actual facilities charge will
be based on Idaho Power's average unit price for the replacement value of new cable at the
time Idaho Power takes ownership of the cable.
In exchange for ldaho Power owning, operating, and maintaining the distribution system located
beyond the POD, the State's total estimated monthly payment is $20,191 ($18,492+ S1,699).
This is only an estimate and the State's monthly facilities charge under Rule M will be based on
the actual cost of the facilities installed.
As part of this fee, Idaho Power's commitment to owning, operating, and maintaining these
facilities serves the State by providing specific benefits. In the event of an outage, the State will
have 24/7 access to knowledgeable and experienced experts to quickly identify and resolve issues
associated with the facilities. Idaho Power maintains an inventory of commonly used equipment,
including transformers, to ensure the State's electric service is quickly restored in the event of an
outage. Additionally, Idaho Power completes periodic and routine detailed visual inspection and
thermal scanning of equipment beyond the POD to ensure the electrical equipment serving the
June 22,2018State of ldaho - Department of Administration Construction Study Version 1
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 1
State operates effectively. This proactively identifies maintenance needs before an unexpected
outage occurs. The State has the choice to install, own, and maintain its own electrical equipment
beyond the primary meter, similar to how HP historically arranged the campus. However, Idaho
Power does not maintain or provide emergency response to customer-owned equipment.
Idaho Power has made considerable efforts to estimate the costs of the necessary upgrades;
however, it is important the State understand that because Idaho Power intends to contract the
work, costs associated with the new facilities can vary substantially depending on numerous
factors including, but not limited to, current inventory cost, contractor availability, and work load.
The below Estimated Schedule is dependent upon the State entering into a Facilities Charge
Service arrangement with ldaho Power pursuant to Rule M.
Table 1 outlines an Estimated Schedule for design, material procurement, and construction. The
schedule allows for six (6) months of outage coordination between award of the contract and
construction per the State's request. If the State desires to compress the outage coordination
schedule, an earlier completion date may be achieved.
Table I
Estimated Schedule
Timeline Milestones
Start
Week
Week
Week
Week
Week
Week
Week
Week
Week
Week
I
5
10
ll
t6
22
22-46
46
52
54
State and Idaho Power agree to and sign Rule M
Facilities Charge Service Consent and
Acknowledgement Form
Scope
Design start
Order long lead material
Design complete
Request for bids for contract construction
Award contract construction
Outage coordination with the State
Construction start*
Construction complete
Commissioning complete
*Construction start date may be earlier depending on outage coordination
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 1
The above Estimated Schedule is an estimate only based on a conceptual design and is therefore
subject to change and not warranted or guaranteed by ldaho Power.
10. CoNcLusroru/Nexr Sreps
Following are the next steps required to move forward with the Project under this Version I (which
would occur if the Commission approves the State's petition for an exemption from the
Commission's Rules in Case No. IPC-E-18-08):
The State confirms its intent to move forward with the Project;
Idaho Power and the State enter a Rule M Facilities Charge Service Consent and
Acknowledgement Form;
o Idaho Power and the State enter an Asset Transfer Agreement.
Unless and until a Rule M Facilities Charge Service Consent and Acknowledgement Form is
entered between the State and Idaho Power, neither party has any legal obligations, express or
implied, related to this Project.
Melanie Pinkston, will serve as the State's Major Customer Representative and point of contact to
begin the Rule M process. She can be reached at [phone], or [e-mail].
Please do not hesitate to contact Melanie with any follow up questions or clarifications.
June 22,2018
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Appendix A
l.P.U.C. No. 29, Tariff No. 101, Rule M
State of ldaho - Department of Administration June22,2018
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ldaho Power Company First Revised Sheet No. M-1
Cancels
|.P.U.C. No. 29, Tariff No. 101 Oriqinal Sheet No. M-1
IDAHO PUBLIC UTILITIES COMMISSIONApproved Effective
August 24,2015 Sept.7,2015
Jean D. JewellSecretary
RULE M
FACILITIES CHARGE SERVICE
This rule applies to eligible customers taking Primary or Transmission Service under Schedules
9, 19 or Special Contract, or Transmission Service under Schedule 24. Eligible Customers may
request that the Company design, install, own, and operate transformers and other facilities beyond the
Point of Delivery that are solely provided to meet the Customer's service requirements. This service is
provided at the Customer's request and at the option of the Company in exchange for the Customer
paying a monthly facilities charge to the Company. Primary and Transmission Service level Customers
not taking facilities charge services are responsible for providing the transformation of power beyond
the Point of Delivery needed to meet the Customer's service requirements. See Rule B.
1. Companv-Owned Facilities Bevond the Point of Deliverv
Under a facilities charge arrangement, the Company will own and operate facilities beyond the
Point of Delivery that are installed to solely benefit the Customer, and the Customer will pay a
monthly facilities charge to the Company based on a percentage of the initial investment cost of
the facilities installed. As part of this arrangement, the Customer agrees to allow ldaho Power
access to the Customer's property to provide installation of facilities, operation and
maintenance, alteration, relocation, upgrade, conversion, and/or removal in order to meet the
Customer's service requirements. The Customer agrees to provide rights-of-way as outlined in
Rule C.
Company-owned facilities beyond the Point of Delivery will be set forth in a Distribution Facilities
lnvestment Report (DFl) provided to the Customer. As the Company's investment in facilities
beyond the Point of Delivery changes in order to meet the Customer's service requirements, the
Company shall notify the Customer of the additions and/or deletions of facilities by forwarding to
the Customer a revised DFl. The Company will also adjust the monthly facilities charge to be
paid by the Customer based on any increase or decrease in the investment cost of the
Company-owned facilities resulting from additions and/or deletions as set forth in the revised
DFI.
2. Alteration and Failure of Companv-Owned Facilities
ln the event the Customer requests the Company to alter (remove, reinstall, or change)
Company-owned facilities beyond the Point of Delivery, the Customer shall pay to the Company
the "non-salvable cost" of such removal, reinstallation, or change. Non-salvable cost as used
herein is comprised of the total depreciated costs of materials, labor, and overheads of the
facilities, less the difference between the salvable cost of material removed, and removal labor
cost including appropriate overhead costs.
Failed equipment will be replaced by the Company as part of providing ongoing operation and
maintenance of Company-owned facilities installed beyond the Point of Delivery. When a failed
piece of equipment is replaced by the Company, the initial investment cost of the failed piecq of
equipment will be removed from the Customer's DFI and replaced with the investment cost of
the new piece of equipment to calculate the Customer's monthly facilities charge.
IDAHO
lssued - August 7,2015
Effective - September 7, 2015
Advice No. 15-09
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company First Revised Sheet No. M-2
Cancels
|.P.U.C. No. 29, Tariff No. 101 Orioinal Sheet No. M-2
IDAHO PUBLIC UTILITIES COMMISSIONApproved EffectiveJune22,2O16 July 16,2016
Jean D. Jewell Secretary
RULE M
FACILITI ES E SERVICE
3. Sale of Companv-Owned Facilities
Customers paying a facilities charge may request to purchase Company-owned facilities
installed beyond the Point of Delivery. All sales of facilities must meet the following provisions:
No mixed ownership of facilities. A Customer purchasing Company-owned facilities
installed beyond the Point of Delivery must purchase all facilities listed on the DFI for
that location.
The Customer must provide the operation and maintenance of all facilities installed
beyond the Point of Delivery after the sale is complete.
The Customer must prepay engineering costs for sales determinations taking greater
than 16 estimated hours of preparation. Sales determinations equal to or less than 16
estimated hours of preparation will be billed to the Customer as part of the sales
agreement, or after the engineering is completed in instances where the sale is not
finalized.
The factors set forth in ldaho Code $ 61-328(3) will be considered as a guide for the sale of
Company-owned facilities installed beyond the Point of Delivery to the customer served by
those facilities. All sales shall be brought before the Commission, whether as an application or
other informal procedure.
4. Monthlv Facilities Charqe Rate
Effective January 1,2012, a facilities charge, as specified in Schedule 66, will be assessed on
each facilities charge customer's monthly billing.
5. Consent and Acknowledoe Form
Prior to entering into a facilities charge arrangement, the Customer and Company must agree to
and sign the Facilities Charge Service Consent and Acknowledgement Form attached to this
rule.
a
b
c.
IDAHO
lssued per Order No. 33514
Effective - July 16, 2016
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company First Revised Sheet No. M-3
Cancels
|.P.U.C. No. 29. Tariff No. 101 Orioinal Sheet No. M-3
IDAHO PUBLIC UTILITIES COMMISSION
Approved Effective
March 5,2012 March 24,2012
Jean D. Jewell Secretary
RULE M
FACI LITI ES CHARGE SERVICE
ldaho Power Companv
Facilities Charqe Service
Consent and Acknowledoement Form
By signing this form, ldaho Power Company ("ldaho Power") and
("Customer") hereby consent to and acknowledge the following:
1. ldaho Power will design, install, own, and operate transformers and other facilities on the
Customer's property which are beyond ldaho Power's Point of Delivery and are solely provided to meet
the Customer's service requirements at the following Customer location:
2. This service is provided at the Customer's request and at the option of ldaho Power in
exchange for the Customer paying a monthly facilities charge to ldaho Power as specified in Schedule
66 of ldaho Power's current and effective tariff.
3. ldaho Power and the Customer agree that this arrangement is provided under the terms
and conditions of Rule M, Facilities Charge Service, of ldaho Power's current and effective tariff.
IDAHO POWER COMPANY CUSTOMER
PRINT NATUE PRINT NAME
TITLE TITLE
IDAHO
lssued - February 24,2012
Effective - March 24,2012
Advice No. 12-04
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
Dated:
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 1
Appendix B-l
ldaho Power Work Order Map of Substation and Campus
June 22,2018State of ldaho - Department of Administration Construction Study Version 1
Page 1 1
APPENDIX B.1
IDAHO POWER COMPANY'S
WORK ORDER MAP OF SUBSTATION AND
GAMPUS IS EXEMPT FROM DISCLOSURE
UNDER IDAHO CODE S 74-1 05(4XB)
BECAUSE IT CONCERNS CRITICAL
INFRASTRUCTURE, THE PUBLIC
DISCLOSURE OF WHICH WOULD
JEOPARDIZE THE SAFETY OF PERSONS,
PROPERTY, OR THE PUBLIC SAFETY.
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 1
Appendix B-2
ldaho Power Work Order Map of Campus
State of ldaho - Department of Administration Construction Study Version 1 June 22,2018
Page 12 Confidential
APPENDIX B.2
IDAHO POWER COMPANY'S
WORK ORDER MAP OF CAMPUS
IS EXEMPT FROM DISCLOSURE UNDER
IDAHO CODE S 74-1 05(4XB) BECAUSE tT
CONCERNS CRITICAL INFRASTRUCTURE,
THE PUBLIG DISGLOSURE OF WHIGH
WOULD JEOPARDIZE THE SAFETY OF
PERSONS, PROPERTY, OR THE PUBLIC
SAFETY.
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 1
Appendix C
Hewlett Packard Site Power Distribution Drawing No. E-5
June 22,2018State of ldaho - Department of Administration Construction Study Version 1
Page 13
APPENDIX C
HEWLETT PAGKARD SITE POWER
DISTRIBUTION DRAWING IS EXEMPT FROM
DtsclosuRE UNDER TDAHO CODE S 74-
105(4XB) BECAUSE rT GONCERNS
CRITICAL INFRASTRUCTURE, THE PUBLIC
DISCLOSURE OF WHICH WOULD
JEOPARDIZE THE SAFETY OF PERSONS,
PROPERTY, OR THE PUBLIC SAFETY.
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 'l
Appendix D
51 36 Vault Specifications
State of ldaho - Department of Administration Construction Study Version 1 June 22,2018
Page 14 Confidential
66-05-10 Revised 07/17 Underground
5136 Vault
The 5 136 vault (approx. 5' x l3' t 6' high) is used as a basement for padmounted equipment when it
needs to be larger than the 5l15. Several 5136 pads are available for common applications and custom
pads can be designed for unusual applications. Contact Methods & Materials for assistance.
Cat. lD Description Traffic Rating Weight CU Code
462',t4
47308
VLT CNRT 5136 BASE SECTION
PAD CNRT 5136 F/PME WHATCH
HS25 19,800|bs
nla 700 lbs
DVs1368
DVs't36P27
Typical 5136 Pad
B"
5136 Vault
Cat. lD 46214
lnside
Height
166"'.
1 66"
60" x 64'
Opening
Pad is S" Thick
5136 Pad for PME Switchgear
Weight = 5,400 lbs
Cat. lD 47637
\\\\-*-/
78"70"
70
Vaults &ffi*
,-l @-otx6
@!
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 1
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June 22,2018State of ldaho - Department of Administration Construction Study Version 1
Page 1 5
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-I9-09
IDAHO POWER COMPANY
ATTACHMENT 3
3Effi*
An toAcoRP company
Construction Study
for
State of ldaho
Department of Admi n istration
in
Boise, ldaho
Version 2 - Point of Delivery at Each Building and Ghiller
Final Report
June 22,2018
State of ldaho - Department of Administration Construction Study 2018
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
TaaLe oF CoNTENTS
Table of Contents..
List of Tables........
List of Appendices
2. Background
3. Required Upgrades to the State's Chinden Campus Electrical System - Version 2
3.1 . Summarv:
3.2. Rule M Facilities Charge Service Work Description: .................
3.3. Rule H New Service Attachments and Distribution Line Installations or
A lterations Work Description :
4. Construction Sequencing
5. Regulation, Permitting, and Other Requirements
6. Customer Requirements................
7. Complexities, Unknowns and Assumptions.......
8. Estimated Costs
8.1 . Project Funding...........
....2
1. lntroduction .3
.J
,4
.4
.5
.6
.8
.8
.8
..9
...............9
8.3. Rule H New Service Attachments and Distribution Line Installations or
Alterations Estimate:
8.4. Comparison to Version I
9. Estimated Schedule
10. Conclusions/Next Steps
8.2. Rule M Facilities Services Charge Estimate
o................ ,
.................. I 0
....... .. . . .. ..... 1 1
..................1 1
.......... ........ 1 1
..................12
June 22,2018State of ldaho - Department of Administration Construction Study Version 2
Page 1
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
LIsT oF TABLES
Table I
Estimated Schedule
LIsT oF APPENDIcES
Appendix A: Rule M
Appendix B: Rule H
Appendix C: Idaho Power Work Order Map
Appendix D: Hewlett-Packard Site Power Distribution Drawing
Appendix E: 5136 Vault Specifications
State of ldaho - Depadment of Administ Construction Study Version 2
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June 22,2018
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
1 lrurRoouc
The State of Idaho - Department of Administration ("State") requested Idaho Power Company
("Idaho Power" or "Company") evaluate the modifications necessary for Idaho Power to own and
operate the electrical system at the State's Chinden Campus (the "Project"), including the
following:
o What, if any, portion of the Chinden Campus' current electrical system meets Idaho
Power's standards;
o Requirements for redesigning the existing electrical distribution system to ldaho Power
construction standards;
o Requirements associated with various metering configurations;
o Estimated costs for design and construction of Idaho Power electrical distribution work;
o Estimated monthly amount of facilities charge service; and,
o Estimatedconstructiontimeline.
Idaho Power is providing two Construction Studies to the State. Version 1 locates the Point of
Delivery (POD) at the Hewlett Packard Substation, and provides the necessary configuration, if
the Idaho Public Utilities Commission ("Commission") grants the State's request for an exemption
to the Commission's master metering rules (Case No. IPC-E-18-08). Version 2 locates the POD
at each building or chiller at the Chinden Campus, and provides the necessary configuration if the
Commission does not grant the State's request in Case No. IPC-E-18-08.
This Construction Study outlines the preliminary costs and timelines associated with Version 2.
This study is not a binding offer, but rather a conceptual study completed by ldaho Power for
purposes of providing the State with information relevant to the State's decision to proceed with
the Project.
2. BncxGRoUND
In November 2017, the State inquired about Idaho Power assuming ownership and providing
ongoing maintenance of the electrical distribution system located at the State's Chinden Campus,
pursuant to Rule M of Idaho Power's Tariff. At that time, Idaho Power informed the State of the
Commission's Master Metering Rules for Electric Utilities (IDAPA 31.26.01) ("Rules") and
discussed Idaho Power's recommendation of requiring separate PODs at each individual
customer's building to comply with the such Rules.
Customers requesting load greater than I MW receive service at the primary voltage, and are
responsible for providing transformation of power to the necessary voltage for use by the customer
beyond the POD. Distribution facilities installed by Idaho Power, up to and including, the meter
at the primary service level customer's POD, are installed pursuant to the terms of Rule H of Idaho
Power's Tariff (Rule H). Customers taking service at a primary voltage level may request that
June 22,2018State of ldaho - Department of Administration Construction Study Version 2
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ldaho Power Company State of ldaho - Depa(ment of Administration Construction Study Version 2
Idaho Power own, operate, and maintain distribution facilities located beyond the POD pursuant
to Rule M.
Customers requesting load less than I MW receive service at a secondary voltage, and all
distribution facilities installed prior to the POD (including transformation facilities) are installed
pursuant to Rule H.
The configuration set forth in this Construction Study (Version 2) anticipates Idaho Power will
separately meter each building and chiller (l I total) located on the State's Chinden Campus. This
configuration allows every tenant on the Chinden Campus to be individually metered by Idaho
Power. For those buildings taking service at a primary voltage, the State requested ldaho Power
design, install, own, and operate transformers and other facilities beyond the POD that are solely
dedicated to the State's service requirements. Facilities located beyond each POD are installed
pursuant to Rule M of Idaho Power's Tarifl and facilities located up to each POD are installed in
accordance with Rule H of Idaho Power's tariff.
Rules H and M are attached as Appendices A and B respectively for the State's reference
3. ReQUIRED UPCNADES TO THE STATE,S GNIruOEN CAMPUS
ElecrRrcAL Svsreu - VenstoN 2
At the State's request, Idaho Power is providing a proposed electrical configuration appropriate
for Idaho Powerto own and operate in accordance with Rules H and M of Idaho Power's Tariff.
A description of the proposed work is broken out below by the applicable Rules.
3.1. Summary:
I Troublemen are on call to provide emergency response
State of ldaho - Depa June22,2018
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
The existing transformers and switches at the Chinden Campus do not meet Idaho Power standards
and must be replaced for Idaho Power to provide facilities charge service. Idaho Power does not
operate ormaintain equipment inside of buildings and is phasing out live-front switchgear. The
State's Chinden Campus distribution wiring is a delta system. The Idaho Power distribution design
standard is a grounded wye system with a system neutral. Idaho Power does not use a delta
distribution design system that does not contain a system neutral. Therefore, Idaho Power does
not retain inventory of delta primary voltage electrical equipment like the transformers installed at
the State's Chinden Campus. Idaho Power employees are trained to operate and maintain a wye
standard primary voltage system.
The existing primary cable at the Chinden Campus also does not meet Idaho Power's standards;
however, Idaho Power is able to take ownership and re-use the cable, where possible, considering
there are no operational differences between the existing cable and Idaho Power's standard cable.
In addition, the existing cable conduit is properly sized and can accommodate Idaho Power's
standard cable, which Idaho Power will use to replace the existing cable if failure occurs in the
future.
Idaho Power's proposed design (work order map) for Version 2 is attached as Appendix C to this
Construction Study for the State's reference.
3.2. Rule M Facilities Charge Service Work Description:
Idaho Power obtained identifying information associated with the State's switches and
transformers, to be removed from the Chinden Campus, from the Hewlett Packard Site Power
Distribution Drawing No. E-5. Hewlett Packard Site Power Distribution Drawing No. E-5 is
attached as Appendix D to this Construction Study for the State's reference. New Idaho Power
devices will be renumbered by ldaho Power.
The following descriptions of work to be completed under a Rule M facilities charge arrangement
start with equipment located at the substation and move clockwise through the Chinden Campus
as shown on the ldaho Power work order map (attached as Appendix C):
a
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
;
I
I
T
3.3. Rule H New Service Attachments and Distribution Line
lnstallations or Alterations Work Description:
The following descriptions of work to be completed under a Rule H distribution facilities
arrangement start with equipment located at the substation and move clockwise through the
Chinden Campus as shown on the Idaho Power work order maps (attached as Appendix C).
a
I
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I
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
a
T
-
June 22,2018State of ldaho - Department of Administration Construction Study Version 2
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
4. CoIISTRUCTION SEQUENCTNG
Cutover to the new system requires multiple isolated outages. The outages will be planned and
coordinated with the State to minimize interruptions. The construction schedule will be adjusted
accordingly to meet the State's request that outages are scheduled at least six months in advance
to avoid interruption of service during the summer months and holidays.
5. ReculenoN, PenmrnNc, AND Ornen REQUTREITIENIS
As described above, the State's metering configuration must be consistent with the Commission's
Rules without need for an exemption.
Idaho Power will work with the State to understand the permitting needs specific to the Project
and, when applicable, jointly coordinate the necessary permit applications. It is also important the
State understand there may be additional regulations and permitting requirements applicable to the
State's facilities which are not Idaho Power's responsibility, and which could impact the estimated
cost and schedule. Although Idaho Power will work with the State on permitting, it is the State's
sole responsibility to understand and comply with all necessary regulations and permits.
6. GusromeR ReouInEMENTS
If the State proceeds with Version 2, the State will transfer ownership of the underground duct
vault and cable to Idaho Power, at no cost to Idaho Power, pursuant to an Asset Transfer
Agreement to be negotiated between the State and Idaho Power. The State will also be required
to provide Idaho Power with the necessary easements on the State's property to accommodate
installation, operation, maintenance, alteration, relocation, upgrades, conversation, and/or removal
of the facilities and equipment associated with the Project, at no cost to Idaho Power. The
easements and executed Asset Transfer Agreement must be in place prior to the Project
construction start date,as shown in the estimated construction schedule set forth in Section 8
In addition, the State will be responsible for other requirements associated with the Project
including, but not limited to, the following:
Disposing the transformers and switches that are removed by ldaho Power;
State of ldaho - Department of Administratio'l lqry!ry ligq Study Version 2 June 22,2018
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
o Replacing damaged landscape and sidewalks;
o Providing and installing service wire from the buildings to the secondary side of the
transformers;
. Verifying to ldaho Power that the State's back-up generators are isolated from back-
feeding to the primary side of the transformers in accordance with applicable codes;
o Providing necessary access for specialized equipment (cranes, line beds, cable pulling
equipment, etc.);
o Allowing Idaho Power to provide a parallel Idaho Power lock, in addition to the State's
lock, on enclosures containing Idaho Power equipment; and,
r Coordinating and communicating outage information with the State's Chinden Campus
tenants.
7. CoUIpLEXITIES. UNKNoWNS AND Ass UMPTIONS
Idaho Power prepared the cost estimate associated with this Version 2 Construction Study in
accordance with the upgrades outlined in Section 3. The cost estimate is conceptual in nature and
does not represent a refined engineering design; as a result, the final configuration and costs may
change. Factors that may contribute to such changes in configuration and cost include, but are not
limited to:
a
a
o
a
a
a
a
a
a
8.
The estimates are based on Idaho Power's construction study estimating tools and not
detailed design estimate;
Contingencies have not been added and are commonly as high as 30%o;
Exact locations of meters and transformers have not been determined;
Idaho Power will likely contract this work and, given the current economy, contractor bids
could escalate substantially;
Commodity markets have at various times, exhibited significant price volatility which
could impact material and salvage values;
Additional equipment to ensure the State's back-up generators are isolated from back-
feeding to the primary side of the transformers is not included;
Adders to account for crews working non-standard hours to minimize impact of outages
on tenants are not included;
Salvage value of removed cable has not been included - salvage value, if any, will be
determined at the time of cable removal and adjusted to cover removal costs; and,
If Rule H work exceeds $1,000,000, a tax gross-up rate of l9%o will be applied.
EsnmarED Cosrs
8.1. Project Funding
The facilities necessary to complete the Project are classified as either facilities charge services
(Rule M), see attached Appendix A, or distribution facilities (Rule H) see attached Appendix B.
Pursuant to the regulatory requirements of Idaho Power's Tariff, these two classifications require
the following distinct funding:
June 22,2018State of ldaho - Department of Administration Construction Studv Version 2
Page 9
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
Facilities charge services (Rule M): under a facilities charge arrangement, Idaho Power
will own and operate facilities beyond the POD that are installed to solely benefit the State,
and the State will pay a monthly facilities charge to Idaho Power based on a percentage of
the initial investment cost of the facilities installed.
o
o Distribution facilities (Rule H): the State is responsible for funding distribution facilities
pursuant to the terms of Rule H of ldaho Power's Tariff. The State must initiate the Rule
H design process by submitting a service request to Idaho Power. Following receipt of the
service request, Idaho Power will design the distribution facilities necessary for the Project.
Upon completion of final design, Idaho Power will provide the State with a firm cost quote
for the distribution facilities ("Rule H Cost Quote") refining the distribution facility
estimates listed in the Cost Estimate Table. Upon receipt of the Rule H Cost Quote, the
State will have 60 days to execute the Rule H Cost Quote and submit a purchase order as
a promise of payment for the full amount of the work.
8.2. Rule M Facilities Services Gharge Estimate:
At the State's request, Idaho Power completed a facilities charge estimate in accordance with Rule
M whereby ldaho Power owns, operates and maintains distribution facilities located beyond the
POD in exchange for the State paying a monthly facilities charge. If Idaho Power and the State
enter into a Rule M arrangement, the State's estimated monthly facilities charge payment is
S I I ,812 based on an estimated installation cost of $837,741 for the facilities described in Section
2.1). The facilities charge rate for all new equipment equals l.4lo/o of the initial investment cost.
The above monthly payment is only an estimate as the State's monthly facilities charge under Rule
M will be based on the actual cost of the facilities installed.
As part of this fee, Idaho Power's commitment to owning, operating, and maintaining these
facilities serves the State by providing specific benefits. In the event of an outage, the State will
have 2417 access to knowledgeable and experienced experts to quickly identify and resolve issues
associated with the facilities. Idaho Power maintains an inventory of commonly used equipment,
including transformers, to ensure the State's electric service is quickly restored in the event of an
outage. Additionally, Idaho Power completes periodic and routine detailed visual inspection and
thermal scanning of equipment beyond the POD to ensure the electrical equipment serving the
State operates effectively. This proactively identifies maintenance needs before an unexpected
outage occurs. The State has the choice to install, own, and maintain its own electrical equipment
beyond the primary meter, similar to how HP historically arranged the campus. However, Idaho
Power does not maintain or provide emergency response to customer-owned equipment.
Idaho Power has made considerable efforts to estimate the costs of the necessary upgrades;
however, it is important the State understand that because Idaho Power intends to contract the
work, costs associated with the new facilities can vary substantially depending on numerous
factors including, but not limited to, current inventory cost, contractor availability, and work load.
State of ldaho - Departmq June 22,2018
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
8.3. Rule H New Service Attachments and Distribution Line
lnstallations or Alterations Estimate:
The preliminary estimated cost for distribution facilities required to upgrade the State's Chinden
Campus, as described in Section 3.3, is S891,081. This estimated cost factors in Idaho Power
using as much of the existing cable as possible. Upon completion of final design, Idaho Power
will provide the State with a Rule H Cost Quote for the necessary distribution facilities ("Rule H
Cost Quote"). The State will be required to fund the Rule H Cost Quote prior to Idaho Power
beginning construction of the upgrades.
Idaho Power will contract the work associated with upgrading the electrical system at the State's
Chinden Campus. The pricing for contracting work can vary substantially depending on contractor
availability and work load.
8.4. Comparison to Version 1:
The total estimate for Version 2 (51,728,822) is S417,314 higher than the estimate for Version I
($ 1 ,3 I 1 ,508). This difference is attributed to several items:
a
a
The scope of work is different for the two versions. Version 2 material costs are $341,400
higher than the Version 1 material costs due to several differences, primarily driven by:
the cost of 7 primary meter packages, two additional 500 KVA transforrners, and 2,000
additional feet of l/0 Al triplex cable. Version 2 also has 140 additional feet of trenched
power cable conduit, three additional 3-phase sectors, and two additional 4-way pad mount
switches.
The labor for Version 2 is $47,700 higher than Version I due to the increased scope of
work.
9. EsnmerED ScHEDULE
The below Estimated Schedule is dependent upon the State entering into a Facilities Charge
Service arrangement with Idaho Power pursuant to Rule M and signing the Rule H cost quote.
Table 1 outlines an Estimated Schedule for design, material procurement, and construction. The
schedule allows for six months of outage coordination between award of the contract and
construction per the State's request. If the State desires to compress the outage coordination
schedule, an earlier completion date may be achieved.
State of ldaho - Department of Administration Construction Study Version 2 June 22,2018
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
Table I
Estimated Schedule
Timeline Milestones
Start
Week
Week
Week
Week
Week
Week
Week
Week
Week
Week
I
5
l0
ll
l6
22
22-46
46
52
54
State and ldaho Power agree to and sign Rule M
Facilities Charge Service Consent and
Acknowledgement Form and the State signs and
funds a Rule H Cost Quote
Scope
Design start
Order long lead material
Design complete
Request for bids for contract construction
Award contract construction
Outage coordination with the State
Construction start*
Construction complete
Commissioning complete
*Construction start date may be earlier depending on outage coordination
The above Estimated Schedule is an estimate only based on a conceptual design, and is therefore
subject to change and not warranted or guaranteed by ldaho Power.
10. Cottclusto NS/NExr Sreps
Following are the next steps required to move forward with the Project under this Version 2 (which
would occur if the Commission does not approve the State's petition for an exemption from the
Commission's Rules in Case No. IPC-E-18-08):
The State confirms its intent to move forward with the Project;
Idaho Power and the State enter a Rule M Facilities Charge Service Consent and
Acknowledgement Form;
Idaho Power provides the State with a Rule H Cost Quote and the State signs and funds the
same;
Idaho Power and the State enter an Asset Transfer Agreement.
Stateofldaho-DepartmentofAdministratio@rsion2 June 22,2018
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ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
Unless and until a Rule M Facilities Charge Service Consent and Acknowledgement Form is
entered between the State and Idaho Power and a Rule H cost quote is signed by the State, neither
party has any legal obligations, express or implied, related to this Project.
Melanie Pinkston, will serve as the State's Major Customer Representative and point of contact to
begin the Rule M process. She can be reached at [phone], or [e-mail].
Please do not hesitate to contact Melanie with any follow up questions or clarifications.
June 22,2018State of ldaho - Deoartment of Administration Construction Study Version 2
Page 13
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
Appendix A
l.P.U.C. No. 29, Tariff No. 101, Rule M
Stateofldaho-DepartmentofAdministratio@rsion2 June 22,2018
Page 14 Confidential
ldaho Power Company First Revised Sheet No. M-1
Cancels
|.P.U.C. No. 29. Tariff No. 101 Orioinal Sheet No. M-1
IDAHO PUBLIC UTILITIES COMMISSIONApproved Effective
August 24,2015 Sept.7,2015
Jean D. Jewell Secretary
RULE M
FACILITIES CHARGE SERVICE
This rule applies to eligible customers taking Primary or Transmission Service under Schedules
9, 19 or Special Contract, or Transmission Service under Schedule 24. Eligible Customers may
request that the Company design, install, own, and operate transformers and other facilities beyond the
Point of Delivery that are solely provided to meet the Customer's service requirements. This service is
provided at the Customer's request and at the option of the Company in exchange for the Customer
paying a monthly facilities charge to the Company. Primary and Transmission Service level Customers
not taking facilities charge services are responsible for providing the transformation of power beyond
the Point of Delivery needed to meet the Customer's service requirements. See Rule B.
1. Companv-Owned Facilities Bevond the Point of Deliverv
Under a facilities charge arrangement, the Company will own and operate facilities beyond the
Point of Delivery that are installed to solely benefit the Customer, and the Customer will pay a
monthly facilities charge to the Company based on a percentage of the initial investment cost of
the facilities installed. As part of this arrangement, the Customer agrees to allow ldaho Power
access to the Customer's property to provide installation of facilities, operation and
maintenance, alteration, relocation, upgrade, conversion, and/or removal in order to meet the
Customer's service requirements. The Customer agrees to provide rights-of-way as outlined in
Rule C.
Company-owned facilities beyond the Point of Delivery will be set forth in a Distribution Facilities
lnvestment Report (DFl) provided to the Customer. As the Company's investment in facilities
beyond the Point of Delivery changes in order to meet the Customer's service requirements, the
Company shall notify the Customer of the additions and/or deletions of facilities by forwarding to
the Customer a revised DFl. The Company will also adjust the monthly facilities charge to be
paid by the Customer based on any increase or decrease in the investment cost of the
Company-owned facilities resulting from additions and/or deletions as set forth in the revised
DFI.
2. Alteration and Failure of Companv-Owned Facilities
ln the event the Customer requests the Company to alter (remove, reinstall, or change)
Company-owned facilities beyond the Point of Delivery, the Customer shall pay to the Company
the "non-salvable cost" of such removal, reinstallation, or change. Non-salvable cost as used
herein is comprised of the total depreciated costs of materials, labor, and overheads of the
facilities, less the difference between the salvable cost of material removed, and removal labor
cost including appropriate overhead costs.
Failed equipment will be replaced by the Company as part of providing ongoing operation and
maintenance of Company-owned facilities installed beyond the Point of Delivery. When a failed
piece of equipment is replaced by the Company, the initial investment cost of the failed piece of
equipment will be removed from the Customer's DFI and replaced with the investment cost of
the new piece of equipment to calculate the Customer's monthly facilities charge.
IDAHO
lssued - August 7,2015
Effective - September 7,2015
Advice No. 15-09
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221West ldaho Street, Boise, ldaho
ldaho Power Company First Revised Sheet No. M-2
Cancels IDAHo pUBLlc UTILITIES couMlsstoN
LP.U.C. No. 29. Tariff No. 101 Oriqinal Sheet No. M-2 Approved Effective
June 22,2016 July 16, 2016
Jean D. JewellSecretary
RULE M
FACILITIES CHARGE SERVICE
3. Sale of Companv-Owned Facilities
Customers paying a facilities charge may request to purchase Company-owned facilities
installed beyond the Point of Delivery. All sales of facilities must meet the following provisions:
No mixed ownership of facilities. A Customer purchasing Company-owned facilities
installed beyond the Point of Delivery must purchase all facilities listed on the DFI for
that location.
The Customer must provide the operation and maintenance of all facilities installed
beyond the Point of Delivery after the sale is complete.
The Customer must prepay engineering costs for sales determinations taking greater
than 16 estimated hours of preparation. Sales determinations equal to or less than 16
estimated hours of preparation will be billed to the Customer as part of the sales
agreement, or after the engineering is completed in instances where the sale is not
finalized.
The factors set forth in ldaho Code $ 61-328(3) will be considered as a guide for the sale of
Company-owned facilities installed beyond the Point of Delivery to the customer served by
those facilities. All sales shall be brought before the Commission, whether as an application or
other informal procedure.
4. Monthlv Facilities Charqe Rate
Effective January 1, 2012, a facilities charge, as specified in Schedule 66, will be assessed on
each facilities charge customer's monthly billing.
5. Consent and Acknowledge Form
Prior to entering into a facilities charge arrangement, the Customer and Company must agree to
and sign the Facilities Charge Service Consent and Acknowledgement Form attached to this
rule.
a
b
c.
IDAHO
lssued per Order No. 33514
Effective - July 16, 2016
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company First Revised Sheet No. M-3
Cancels
|.P.U.C. No. 29, Tariff No. 101 Orioinal Sheet No. M-3
!DAHO PUBLIC UT!LITIES COMMISSIONApproved Effective
March 5,2012 March 24,2012
Jean D. JewellSecretary
RULE M
FACILITIES CHARGE SERVICE
ldaho Power Companv
Facilities Charqe Service
Consent and Acknowledoement Form
By signing this form, ldaho Power Company ("ldaho Power") and
("Customer") hereby consent to and acknowledge the following:
1. ldaho Power will design, install, own, and operate transformers and other facilities on the
Customer's property which are beyond ldaho Power's Point of Delivery and are solely provided to meet
the Customer's service requirements at the following Customer location:
2. This service is provided at the Customer's request and at the option of ldaho Power in
exchange for the Customer paying a monthly facilities charge to ldaho Power as specified in Schedule
66 of ldaho Power's current and effective tariff.
3. ldaho Power and the Customer agree that this arrangement is provided under the terms
and conditions of Rule M, Facilities Charge Service, of ldaho Power's current and effective tariff.
Dated
IDAHO POWER COMPANY CUSTOMER
PRINT NAME PRINT NAME
TITLE TITLE
IDAHO
lssued - February 24,2012
Effective - March 24,2012
Advice No. 12-04
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
Appendix B
l.P.U.C. No. 29, Tariff No. 101, Rule H
June 22,2018State of ldaho - Department of Administration Construction Study Version 2
Page 15
ldaho Power Company Second Revised Sheet No. H-1
Cancels
|.P.U.C. No. 29, Tariff No. 101 First Revised Sheet No. H-1
IDAHO PUBLIC UTILITIES COMMISSIONApproved Effective
l{lay 21,2018 June 1,2018
Per O.N. 34046
Diane M. Hanian Secretary
RULE H
NEW SERVICE ATTACHMENTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
This rule applies to requests for electric service under Schedules 1 , 3, 4,5, 6, 7, 8, 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.
1. Definitions
Additional Applicant is a person or entity whose Application requires the Company to provide
new or relocated service from an existing section of distribution facilities with a Vested lnterest.
Alteration is any change or proposed change to existing distribution facilities. An alteration may
include Relocation, Upgrade, Conversion, and/or removal.
Apolication is a request by an Applicant or AdditionalApplicant for new electric service from the
Company. The Company, at its discretion, may require the Applicant or Additional Applicant to
sign a written application.
Companv Betterment is that portion of the Work Order Cost of a Line lnstallation and/or
Alteration that provides a benefit to the Company not required by the Applicant or Additional
Applicant. lncreases 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. lf, 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 projectwhich will add a load greaterthan 100 kilowatts, the Companywill not
consider the work necessitated by the load increase to be a Company Betterment.
Connected Load is the total nameplate kW rating of the electric loads connected for commercial,
industrial, or irrigation service. Connected Load for residences is considered to be 25 kW for
residences with electric space heat and 15 kW for all other residences.
Conversion is a request by a customer to replace overhead facilities with underground facilities.
Cost Quote is a written cost estimate provided by the Company that must be signed and paid by
the Applicant or Additional Applicant prior to the start of construction. Cost Quotes are derived
from Work Order Cost estimates.
Easement is the Company's legal right to use the real property of another for the purpose of
installing or locating electric facilities.
IDAHO
lssued per Order No. 34046
Effective - June 1,2018
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
Applicant is a person or entity whose Application requires the Company to provide new or
relocated service from distribution facilities that are free and clear of any Vested lnterest.
ldaho Power Company
1 o nal Sheet No.
RULE H
NEW SERVI CE ATTACHMENTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)
1. Definitions(Continued)
Fire Protection Facilities are water pumps and other fire protection equipment, served
separately from the Applicant's other electric load, which operate only for short periods of time in
emergency situations and/or from time to time for testing purposes.
Line lnstallation is any installation of new distribution facilities owned by the Company. Line
lnstallations are exclusive of Service Attachments and eligible for Vested lnterest Refunds.
Line lnstallation Allowance is the portion of the estimated cost of a Line lnstallation funded by
the Company.
Line.lnstallation Charqe is the partially refundable charge assessed an Applicant or Additional
Applicant whenever a Line lnstallation is built for that individual.
Local lmprovement District is an entity created by an authorized governing body under the
statutory procedures set forth in ldaho code, Title 50, Chapter 17 or ldaho Code $ 40-1322. For
the purpose of Rule H, the term LID also includes Urban Redevelopment projects set forth in
ldaho Gode. Title 50, Chapter 20.
Mu]tip_lg. 9ccupancy Proiects are projects that are intended to be occupied by more than four
owners or tenants. Examples include, but are not limited to condominiums and apartments.
Point of Deliverv is the junction point between the facilities owned by the Company and the
facilities owned by the customer; OR the point at which the Company's lines first become
adjacent to the customer's property; OR as otherwise specified in the Company's tarffi,
Prior Riqht of Occupancv is a designated area within the public road right-of-way where the
Company and the Public Road Agency have agreed that the costs of the Relocation of facilities
in the designated area will be borne by the Public Road Agency. For example, a Prior Right of
Occupancy may be created when the Public Road Agency expands the public road right-of-way
to encompass a Company Easement without compensating the Company for acquiring the
Easement but the padies agree in writing that the subsequent Relocation of distribution facilities
within the designated area will be borne by the Public Road Agency.
Private Feneficiarv is any individual, firm or entity that provides funding for road improvements
performed by a Public Road Agency or compensates the Company for the Relocation of
distribution facilities as set forth in Section 10. A Private Beneficiary may include, but is not
limited to, real estate developers, adjacent landowners, or existing customers of the Company.
Public Road Aqengy is any state or local agency which constructs, operates, maintains or
administers public road rights-of-way in ldaho, including where appropriate the ldaho
Transportation Department, any city or county street department, or a highway district.
IDAHO PUBLIC UTILITIES COMMISSIONApproved Effective
Nov.30,2009 Dec. 1,2009
Per O.N. 30955
Jean D. Jewell Secretary
IDAHO
lssued - November 27,20Q9
Effective - December 1, 2009
lssued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, lD
ldaho Power Company First Revised Sheet No. H-3
Cancels
|.P.U.C. No. 29. Tariff No. 101 Oriqinal Sheet No. H-3
IDAHO PUBLIC UTILITIES COMMISSION
Approved Effective
March 12,2012 March 15,2012
Per O.N. 32473
Jean D. JewellSecretaryRULE H
NEW SERVI CE ATTACH MENTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)
1. Definitions (Continued)
Relqcation is a change in the location of existing distribution facilities.
Residence is a structure built primarily for permanent domestic dwelling. Dwellings where
tenancy is typically less than 30 days in length, such as hotels, motels, camps, lodges, clubs,
and structures built for storage or parking do not qualify as a Residence.
Service Attachment is the interconnection between the Company's distribution system and the
Applicant's or AdditionalApplicant's Point of Delivery.
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 2O0 amperage meter base.
Subdivision is the division of a lot, tract, or parcel of land into two or more parts for the purpose
of transferring ownership or for the construction of improvements thereon that is lawfully
recognized, platted and approved by the appropriate governmental authorities.
Temporary Line lnstallation is a Line lnstallation for electric service of 18 calendar months or
less in duration.
Temporary Service Attachment is a Service Attachment to a customer-provided temporary pole
which typically furnishes electric service for construction.
Terminal Facilities include transformer, meter, overhead service conductor, or underground
conduit (where applicable). These facilities are not eligible for Vested lnterest Refunds.
Underqround Service Attachment Charoe is the non-refundable charge assessed an Applicant
or Additional Applicant whenever new underground service is required by a customer attaching
to the Company's distribution system.
IDAHO
lssued per Order No. 32473
Effective - March 15,2012
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company Seventh Revised Sheet No. H-4
Cancels
I.P.U.C. No. 29. Tariff No. 101 Sixth Revised Sheet No. H-4
IDAHO PUBLIC UTILITIES COMMISSIONApproved EffectiveFeb.26,2018 March 15,2018
Diane M. Hanian Secretary
RULE H
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)
1. Definitions(Continued)
Unusual Conditions are construction conditions not normally encountered, but which the
Company may encounter during construction which impose additional, project-specific costs.
These conditions may include, but are not limited to: frost, landscape replacement, road
compaction, pavement replacement, chip-sealing, rock digging/trenching, boring, nonstandard
facilities or construction practices, and other than available voltage requirements
Costs associated with unusual conditions are separately stated and are subject to refund if not
encountered. lf unusual conditions are not encountered, the Company will issue the appropriate
refund within 90 days of completion of the project
Uoqrade is a request by a customer to increase capacity and/or size of Company-owned
distribution facilities. Upgrades are eligible for Vested lnterest Refunds.
Vested lnterest is the right to a refund that an Applicant or Additional Applicant holds in a
specific section of distribution facilities when Additional Applicants attach to that section of
d istribution facilities.
Vested Interest Charqe is an amount collected from an Additional Applicant for refund to a
Vested lnterest Holder.
Vested lnterest Holder is an entity that has paid a refundable Line lnstallation Charge to the
Company for a Line lnstallation. A Vested lnterest Holder may also be an entity that has paid a
refundable charge to the Company under the provisions of a prior rule or schedule.
Vested lnterest Refund is a refund payment to an existing Vested lnterest Holder resulting from
a Vested lnterest Charge to an Additional Applicant.
Vested lnterest Portion is that part of the Company's distribution system in which a Vested
lnterest is held.
Work Order Cost is a cost estimate performed by the Company for a specific request for service
by an Applicant or Additional Applicant. The Work Order Cost will include general overheads of
16.62 percent.
IDAHO
lssued - December 29,2017
Effective - March 15,2018
Advice No. 17-06
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company First Revised Sheet No. H-5
Cancels
|.P.U.C. No. 29, Tariff No. 101 OrioinalSheet No. H-5
IDAHO PUBLIC UTILITIES COMMISSIONApproved Effective
March 12,2012 March 15,2412
Per O.N. 32473
Jean D. JewellSecretaryRULE H
NEW SERVICE ATTACHMENTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)2. General Provisions
Cost lnformation. The Company will provide preliminary cost information addressing in
the charges contained in this rule, to potential Applicants and/or Additional Applicants.
This preliminary information will not be considered a formal Cost Quote and will not be
binding on the Company or Applicant but rather will assist the Applicant or Additional
Applicant in the decision to request a formal Cost Quote. Upon receiving a request for a
formal Cost Quote, the Applicant or Additional Applicant will be required to prepay non-
refundable engineering costs to the Company. A Cost Quote will be binding in
accordance with its terms.
b
c.
Ownership. The Company will own all distribution line facilities and retain all rights to
them.
Riohts-of-Wav and Easements. The Company will construct, own, operate, and
maintain lines only along public streets, roads, and highways that the Company has the
legal right to occupy, and on public lands and private property across which rights-of-
way or easements satisfactory to the Company will be obtained at the Applicant's or
Additional Applicant's expense.
Removals. The Company reserves the right to remove any distribution facilities that
have not been used for 1-year. Facilities shall be removed only after providing 60 days
written notice to the last customer of record and the owner of the property served.
Propertv Specifications. Applicants or Additional Applicants must provide the Company
with final property specifications as required and approved by the appropriate
governmental authorities. These specifications may include but are not limited to:
recorded plat maps, utility easements, final construction grades, property pins and proof
of ownership.
Undeveloped Subdivisions. When electric service is not provided to the individual
spaces or lots within a Subdivision, the Subdivision will be classified as undeveloped.
Mobile Home Courts. Owners of mobile home courts will install, own, operate, and
maintain all termination poles, pedestals, meter loops, and conductors from the Point of
Delivery.
Conditions for Start of Construction. Construction of Line lnstallations and Alterations
will not be scheduled until the Applicant or Additional Applicant pays the appropriate
charges to the Company.
Terms of Pavment. All payments listed under this section will be paid to the Company in
cash, a minimum of 30 days and no more than 120 days, prior to the start of Company
construction, unless mutually agreed otherwise.
a
d
e.
f
g
h
IDAHO
lssued per Order No. 32473
Effective - March 15,2012
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221West ldaho Street, Boise, ldaho
t.
ldaho Power Company First Revised Sheet No. H-6
Cancels
|.P.U.C. No. 29, Tariff No. 101 Oriqinal Sheet No. H-6
IDAHO PUBLIC UTILITIES GOMMISSION
Approved Effective
March 12,2012 March 15,2012
Per O.N. 32473
Jean D. JewellSecretaryRULE H
NEW SERVICE ATTACHMENTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)
2. General Provisions (Continued)
lnterest on Pavment. lf the Company does not start construction on a Line lnstallation or
Alteration within 30 days after receipt of the construction payment, the Company will
compute interest on the payment amount beginning on the 31st day and ending once
Company construction actually begins. lnterest will be computed at the rate applicable
under the Company's Rule L. lf this computation results in a value of $10.00 or more,
the Company will pay such interest to the Applicant, Additional Applicant, or subdivider.
An Applicant, Additional Applicant, or subdivider may request to delay the start of
construction beyond 30 days after receipt of payment in which case the Company will
not compute or pay interest.
Fire Protection Facilities. The Company will provide service to Fire Protection Facilities
when the Applicant pays the full costs of the Line lnstallation including Terminal
Facilities, less Company Betterment. These costs are not subject to a Line lnstallation
Allowance, but are eligible for Vested lnterest Refunds under Section 8.a.
Customer Provided Trench Diooinq and Backfill. The Company will, at its discretion,
allow an Applicant, Additional Applicant or subdivider to provide trench digging and
backfill. ln a joint trench, backfill must be provided by the Company. Costs of customer-
provided trench and bacKillwill be removed from or not included in the Cost Quote and
will not be subject to refund.
3. Line lnstallation Charqes
lf a Line lnstallation is required, the Applicant or Additional Applicant will pay a partially
refundable Line lnstallation Charge equal to the Work Order Cost less applicable Line
lnstallation Allowances identified in Section 7.
k
L
IDAHO
lssued per Order No. 32473
Effective - March 15,2012
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
'1221 West ldaho Street, Boise, ldaho
J.
RULE H
NEW SERVICE ATTACHMENTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)
4. Service Attachment Charqes
a Overhead Service Attachment Charoe. lf an overhead Service Attachment is required,
the Applicant or Additional Applicant will pay a non-refundable Service Attachment
Charge equal to the Work Order Cost less applicable Service Attachment allowances
identified in Section 7.
Underqround Service Attachment Charoe. Each Applicant or Additional Applicant will
pay a non-refundable Underground Service Attachment Charge for attaching new
Terminal Facilities to the Company's distribution system. The Company will determine
the location and maximum length of service cable.
Sinqle Phase 400 Amps or Less and Sinqle Phase Self-Contained Multiple Meter
Bases 500 Amps or Less.
Underground Service Cable (Base charge plus Distance charge)
Base charge from:underground $ 22.00
overhead including 2" riser $573.00
overhead including 3" riser $826.00
ldaho Power Company Tenth Revised Sheet No. H-7
Cancels
|.P.U.C. No. 29. Tariff No. 101 Ninth Revised Sheet No. H-7
Distance charge (per foot)
Company lnstalled Facilities with
'1l0 underground cable
4/0 underground cable
350 underground cable
IDAHO PUBLIC UTILITIES COMMISSIONApproved EffectiveFeb.26,2018 March15,2018
Diane M. Hanian Secretary
$ 10.00
$ 10.68
$ 12.82
b
Customer Provided Trench & Conduit with:
1/0 underground cable
4/0 underground cable
350 underground cable
ii. All Three Phase. Sinole Phase Greater than 400 Amps, and Sinqle Phase Self-
$ 3.18$ 3.86$ 5.25
Contained Multiple Meter Bases Greater Than 500 Amps.
lf a three phase, single phase greater than 400 amp, or single phase self-
contained multiple meter base greater than 500 amp underground Service
Attachment is required, the Applicant or Additional Applicant will pay a non-
refundable Underground Service Attachment Charge equal to the Work Order
Cost.
IDAHO
lssued - December 29,2017
Effective - March 15,2018
Advice No. 17-06
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
i.
ldaho Power Company Ninth Revised Sheet No. H-8
Cancels
|.P.U.C. No. 29. Tariff No. 101 Eiohth Revised Sheet No. H-8
IDAHO PUBLIC UTILITIES COMMISSIONApproved EffectiveFeb.26,2018 March15,2018
Diane M. Hanian Secretary
RULE H
NEW SERVICE ATTACHMENTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)
5. Vested lnterest Charqes
Additional Applicants connecting to a vested portion of a Line lnstallation will pay a Vested
lnterest Charge to be refunded to the Vested lnterest Holder. Additional applicants will have
two payment options:
Option One - An Additional Applicant may choose to pay an amount determined by this
equation:
Vested lnterest Charge = A x B x C where;
A = Load Ratio: AdditionalApplicant's Connected Load divided by the sum of
AdditionalApplicant's Connected Load and Vested lnterest Holder's load.
B = Distance Ratio: AdditionalApplicant's distance divided by originaldistance.
C = Vested lnterest Holder's unrefunded contribution
Option Two - An Additional Applicant may choose to pay the current Vested lnterest, in
which case the Additional Applicant will become the Vested lnterest Holder and, as
such, will become eligible to receive Vested lnterest Refunds in accordance with Section
8.a.
lf Option One is selected, the Additional Applicant has no Vested lnterest and the previous
Vested lnterest Holder remains the Vested lnterest Holder. The Vested lnterest Holder's
Vested lnterest will be reduced by the newest Additional Applicant's payment.
The Vested lnterest Charge will not exceed the sum of the Vested lnterests in the Line
lnstallation. lf an Additional Applicant connects to a portion of a vested Line lnstallation which
was established under a prior rule or schedule, the Vested lnterest Charges of the previous rule
or schedule apply to the AdditionalApplicant.
6. Other Charoes
Alteration Charoes. lf an Applicant or Additional Applicant requests a Relocation,
Upgrade, Conversion or removal of Company facilities, the Applicant or Additional
Applicant will pay a non-refundable charge equalto the Cost Quote.
Enqineerino Charqe. Applicants or Additional Applicants will be required to prepay all
engineering costs for Line lnstallations and/or Alterations greater than 16 estimated
hours. Estimates equal to or less than 16 hours will be billed to the Applicant or
Additional Applicant as part of the construction costs, or after the engineering is
completed in instances where construction is not requested. Engineering charges will
be calculated at $74.00 per hour.
a.
b.
IDAHO
lssued - December 29,2017
Effective - March 15,2018
Advice No. 17-06
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company Seventh Revised Sheet No. H-9
Cancels
|.P.U.C. No. 29. Tariff No. 101 Sixth Revised Sheet No. H-9
IDAHO PUBLIC UTILITIES COMMISSIONApproved EffectiveFeb.26,2018 March 15,2018
Diane M. Hanian Secretary
RULE H
NEW SERVICE ATTACHMENTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)
5. Other Charqes (Continued)
c.Enqineerinq Charoes for Aqencies and Taxino Districts of the State of ldaho. Under the
authority of ldaho Code Section 567-2302, an agency or taxing district of the State of
ldaho may invoke its right to decline to pay engineering charges until the engineering
services have been performed and billed to the agency or taxing district. Any state
agency or taxing district that claims it falls within the provisions of ldaho Code 567-2302
must notify ldaho Power of such claim at the time ldaho Power requests prepayment of
the engineering charges. ldaho Power may require that the state agency or taxing
district's claim be in writing. lf the state agency or taxing district that has invoked the
provisions of ldaho Code Section 567-2302 does not pay the engineering charges within
the 60 day period as provided in that statute, all the provisions of that statute will apply.
Joint Trench Charqe. Applicants, Additional Applicants, and subdividers will pay the
Company for trench and backfill costs included in the Cost Quote. ln the event the
Company is able to defray any of the trench and backfill costs by sharing a trench with
other utilities, the cost reduction will be included in the Cost Quote.
Riqhts-of-Wav and Easement Charoe. Applicants or Additional Applicants will be
responsible for any costs associated with the acquisition of rights-of-way or easements.
Temporarv Line lnstallation Charoe. Applicants or Additional Applicants will pay the
installation and removal costs of providing Temporary Line lnstallations.
Temoorarv Service Attachment Charoe. Applicants or Additional Applicants will pay for
Temporary Service Attachments as follows:
i. Underqround - $58.00
The Customer-provided pole must be set within two linear feet of the Company's
existing transformer or junction box.
d
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IDAHO
lssued - December 29,2017
Effective - March 15, 2018
Advice No. 17-06
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
IDAHO PUBLIC UTILITIES COMMISSIONApproved EffectiveFeb.26,2018 March15,2018
Diane M. Hanian Secretary
RULE H
NEW SERVICE ATTAC HIVFNTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)
5. Other Charqes (Gontinued)
g. Temporarv Service Attachment Charqe (Continued)
ii. Overhead - $243.00
The Customer-provided pole shall be set in a location that does not require more
than 100 feet of #2 aluminum service conductor that can be readily attached to
the permanent location by merely relocating it.
The electrical facilities provided by the Customer on the pole shall be properly
grounded, electrically safe, meet all clearance requirements, and ready for
connection to Company facilities.
The Customer shall obtain all permits required by the applicable state, county, or municipal
governments and will provide copies or verification to the Company as required. The above
conditions must be satisfied before the service will be attached.
Temporarv Service (Overhead or Underqround). Overhead Permanent. and Customer
Provided Trench lnspection Return Trip Charoe. A Return Trip Charge of $58.00 will be
assessed each time Company personnel are dispatched to the job site, but are unable to
connect the service. The charge will be billed after the conditions have been satisfied
and the connection has been made.
Unusual Conditions Charqe. Applicants, Additional Applicants, and subdividers will pay
the Company the additional costs associated with any Unusual Conditions included in
the Cost Quote. This payment, or portion thereof, will be refunded to the extent that the
Unusual Conditions are not encountered.
ln the event that the estimate of the Unusual Conditions included in the Cost Quote is equal to or
greater than $10,000, the Applicant, Additional Applicant or subdivider may either pay for the Unusual
Conditions or may furnish an lrrevocable Letter of Credit drawn on a local bank or local branch office
issued in the name of ldaho Power Company for the amount of the Unusual Conditions. Upon
completion of that portion of the project which included an Unusual Conditions estimate, ldaho Power
Company will bill the Applicant, Additional Applicant or subdivider for the amount of Unusual Conditions
encountered up to the amount established in the lrrevocable Letter of Credit. The Applicant, Additional
Applicant or subdivider will have 15 days from the issuance of the Unusual Conditions billing to make
payment. lf the Applicant, Additional Applicant or subdivider fails to pay the Unusual Conditions bill
within 15 days, ldaho Power will request payment from the bank.
i.
IDAHO
lssued - December 29,2017
Effective - March 15,2018
Advice No. 17-06
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company Seventh Revised Sheet No. H-10
Cancels
|.P.U.C. No. 29. Tariff No. 101 Sixth Revised Sheet No. H-l0
h.
RULE H
NEW SERVICE ATTACHMENTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)
6. Other Charqes (Continued)
Underoround Service Return Trio Charqe. When a residential Customer agrees to
supply the trench, backfill, conduit, and compaction for an underground service, an
Underground Service Return Trip Charge of $95.00 will be assessed each time the
Company's installation crew is dispatched to the job site at the Customer's request, but
is unable to complete the cable installation and energize the service.
7. Line lnstallation and Service Attachment Allowances
The Company will contribute an allowance toward the Terminal Facilities and Line lnstallation
costs necessary for Line lnstallations and/or Service Attachments. Allowances are based on
the cost of providing and installing Standard Terminal Facilities for single phase and three
phase services.
Allowances for Overhead and Underqround Line lnstallations and Overhead Service
Attachments
Class of Service Maximum Allowance per Service
ldaho Power Company Tenth Revised Sheet No. H-11
Cancels
|.P.U.C. No. 29, Tariff No. 101 Ninth Revised Sheet No. H-11
Residential:
Schedules 1, 3, 4, 5, 6
Non-residence
Non-residential:
Schedules 7,8,9,24
Single Phase
Three Phase
IDAHO PUBLIC UTILITIES COMMISSIONApproved Effective
tfiay 21,2018 June 1,2018
Per O.N. 34046
Diane M. Hanian Secretary
$2,353.00
0.00$
$2,353.00
$5,604.00
b
Large Power Service
Schedule 19 Case-By-Case
Allowances for Subdivisions and Multiple Occupancv Proiects
Developers of Subdivisions and Multiple Occupancy Projects will receive a $2,353.00
allowance for each single phase transformer installed within a development and a
$5,604.00 allowance for each three phase transformer installed within a development.
Subdividers will be eligible to receive allowances for Line lnstallations inside residential
and non-residential subdivisions.
IDAHO
lssued per Order No. 34046
Effective - June 1,2018
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
j
a.
ldaho Power Company
].P.U.C. No. 29. Taritf No. 101 Oriqinal Sheet No. H-12
8. Refunds
IDAHO PUBLIC UTILITIES COMMISSION
Approved Effective
Nov.30,2009 Dec. 1,2009
Per O.N. 30955
Jean D. Jewe!!SecretaryRULE H
NEW SERVICE ATTACHMENTS
ANp prsTRtBUT|ON L|NE
INSIALLATIONS OR
ALTERAT-IONS
(Continued)
Vested lnlerest Refunds. Vested lnterest Refunds will be paid by the Company and
funded by the AdditionalApplicant's Vested lnterest Charge as calculated in accordance
with Section 5. The initialApplicant will be eligible to receive refunds up to 80 percent of
their original construction cost. Additional Applicants that become Vested lnterest
Holders will be eligible to receive refunds up to their total contribution less 20 percent of
the original construction cost.
A Vested lnterest Holder and the Company may agree to waive the Vested lnterest
payment requirements of Additional Applicants with loads less than an agreed upon
level, Walved Additional Applicants will not be considered Additional Applicants for
purposes of Section 8.a.i. (1) below,
i. Vegted lnterest Refund Limitations
(1). Vested lnterest Refunds will be funded by no more than 4 Additional
Applicants during the S-year period following the completion date of the
Line lnstallation for the initial Applicant.
ln no circumstance will refunds exceed 100 percent of the refundable
portion of any party's cash payment to the Company.
b. Subdivision Refunds.
Applicants will be eligible for Vested lnterest Refunds for facilities installed inside
Subdivisions if the construction was NOT part of the initial Line lnstallation.
Customers requesting additional Line lnstallations within a Subdivision will be
considered new Applicants and become eligible for Vested lnterest Refunds,
A subdivider witl be eligible for Vested lnterest Refunds for payments for Line
lnstallations outside subdivisions.
a.
(2)
t.
il.
IDAHO
lssued - November 27 ,2009
Effective - December 1, 2009
lssued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
'1221 West ldaho Street, Boise, lD
ldaho Power Company
l.P.U.C. No. 29, Tariff No. 101
IDAHO PUBLIC UTILITIES COMMISSION
Approved Effective
Nov.30,2009 Dec. 1,2009
Per O.N. 30955
Jean D. JewellSecretary
OriqinalSheet No. H l3
RULE H
NEW SERVI CE ATTACHMENTS
AND DISTRIBUTION LINE
TNSTALLATTONS._QB
ALTERATIONS
(Continued)
9. L.9.c-4J,lmprovement 9lg,tricG
Unless specifically provided for under this paragraph, a Local lmprovement District wlll be
provided service underthe generalterms of this rule.
The Company witl provide a cost estimate and feasibility study for a Local lmprovement District
within 120 days after receiving the resolution from the requesting governing body. The Cost
Quote will be based on Work Order Costs and will not be considered binding on the Company if
construction is not commenced within 6 months of the submission of the estimate for reasons
not within the control of the Company. The governing body issuing the resolution will pay the
Company for the costs of preparing the cost estimate and feasibility study regardless of whether
the Line lnstallation or Alteration actually takes place.
After passage of the Local lmprovement District ordinance, the Company will construct the Line
lnstallation or Alteration. Upon completion of the project, the Company will submit a bill to the
Local lmprovement District for the actual cost of the work performed, including the costs of
preparing the cost estimate and feasibility study. lf the actual cost is less than the estimated
cost, the Local lmprovement District will pay the actual cost. lf the actual cost exceeds the
estimated cost, the Local lmprovement District will pay only the estimated cost. The governing
body will pay the Company within 30 days after the bill has been submitted.
A Local lmprovement District will be eligible for a Line lnstallation Allowance for any new load
connecting for service upon the completion of the Line lnstallation. A Local lmprovement
Diskict will retain a Vested lnterest in any Line lnstallation to the Local lmprovement District. A
Local Improvement District may waive payments for Vested lnterest from Additional Applicants
within the Local lmprovement District,
IDAHO
lssued - November 27,2009
Effective - December 1, 2009
lssued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, lD
ldaho Power Company Second Revised Sheet No. H-14
Cancels
LP.U.C. No. 29, Tariff No. 101 First Revised Sheet No. H-14
IDAHO PUBLIC UTILITIES COMMISSION
Approved Effective
July 18,2012 July 12,2012
Per O.N. 32592
Jean D. JewellSecretaryRULE H
NEW SERVICE ATTACH MENTS
AND DISTRIBUTION LINE
INSTALLATIONS OR
ALTERATIONS
(Continued)
10. Relocations in Public Road Riqhts-of-Wav
The Company often locates its distribution facilities within state and local public road rights-of-
way under authority of ldaho Code $ 62-705 (for locations outside ldaho city limits) and the
Company's city franchise agreements (for locations within ldaho city limits). When the
Company is notified of a road improvement project pursuant to ldaho Code $ 40-210, the
Company will meet with the Public Road Agency as provided in ldaho Code to S 40-210.
lf a Public Road Agency determines that the Company's facilities incommode the public use of
any road, highway, or street, the Public Road Agency can require the company to relocate or
remove the facilities. lf a Public Road Agency determines that the Company's facilities must be
relocated or removed because they incommode the public use of the road, highway, or street,
the Company will relocate its distribution facilities from or within the public road rights-of-way
and the Company will bear the costs of such relocation.
lf one or more Private Beneficiaries has requested that the Company's facilities be relocated or
removed, the Company will use reasonable efforts to recover that portion of the total Relocation
or removal costs attributable to the request from the Private Beneficiaries. lf the Private
Beneficiaries dispute the Company's calculation of the Private Beneficiaries' cost responsibility,
either the Company or the affected Private Beneficiaries may initiate a proceeding to have the
Commission establish the reasonableness of the Company's calculation of the Relocation or
removal cost responsibility as between the Company and the Private Beneficiaries.
11. ExistinqAqreements
This rule shall not cancel existing agreements, including refund provisions, between the
Company and previous Applicants, or Additional Applicants. All Applications will be governed
and administered under the rule or schedule in effect at the time the Application was received
and dated by the Company.
IDAHO
lssued per Order No. 32592
Effective - July 12,2012
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
Appendix C
ldaho Power Work Order Map
State of ldaho - Department of Administration Construction Study Version 2 June 22,2018
Page 16 Confidential
APPENDIX C
IDAHO POWER COMPANY'S
WORK ORDER MAP IS EXEMPT FROM
DlsclosuRE UNDER TDAHO CODE S 74-
105(4XB) BECAUSE rT CONCERNS
GRITICAL INFRASTRUCTURE, THE PUBLIC
DISCLOSURE OF WHICH WOULD
JEOPARDIZE THE SAFETY OF PERSONS,
PROPERTY, OR THE PUBLIC SAFETY.
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
Appendix D
Hewlett Packard Site Power Distribution Drawing No. E-5
June 22,2018State of ldaho - Department of Administration Construction Study Version 2
Page 17
APPENDIX D
HEWLETT PACKARD SITE POWER
DISTRIBUTION DRAWING IS EXEMPT FROM
DtscLosuRE UNDER TDAHO CODE S 74-
105(4XB) BECAUSE rr CONCERNS
CRITICAL INFRASTRUGTURE, THE PUBLIC
DISCLOSURE OF WHICH WOULD
JEOPARDIZE THE SAFETY OF PERSONS,
PROPERTY, OR THE PUBLIC SAFETY.
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
Appendix E
5 I 36 Vault Specifications
State of ldaho - Department of Administration Construction Study Version 2 June 22,2018
Page 18 Confidential
66-05-1 0 Revised 07/17 Underground
5136 Vault
The 5136 vault (approx. 5' x 13' " 6' high) is used as a basement for padmounted equipment when it
needs to be larger than the 5l15. Several 5136 pads are available for common applications and custom
pads can be designed for unusual applications. Contact Methods & Materials for assistance.
Cat. lD Description Traffic Rating Weight CU Code
46214
47308
VLT CNRT 5,I36 BASE SECTION
PAD CNRT 5136 F/PME WHATCH
HS25 '19,8001bs
7,700 lbs
DV51 368
DVs1 36P2nla
Typical 5'136 Pad
\
5136 Vault
Cat. lD 46214
B'
78"70"
lnside
166"'..
too
60" x 64"
Opening
Pad is S" Thick
5136 Pad for PME Switchgear
Weignt = 5.400 lbs
Cat. lD 47637
70"
Vaults Sffi*
ll
4"
t
,t"l
I
(o-otx6
@Io
ldaho Power Company State of ldaho - Department of Administration Construction Study Version 2
This page left blank intentionally.
June 22,2018State of ldaho - Department of Administration Construction Study Version 2
Page 19
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
GASE NO. !PC-E-18-08
IDAHO POWER COMPANY
ATTACHMENT 4
REQUEST NO.4: Please provide a detailed description of thc methodology to allocate
the Idaho Power Carnpus-wide billing to all the sub-entities (including Ieases). This description
should provide enough detail so it describes the calculations from the data collected fiorn all the
sub-meters (identified by item tag) and how this data rvill be used to reconcile and allocate the
diftercnt charges rvithin the overall campus-wide bill (i.e. customer, demand. errergy) to all the
sub-entities.
IDOA ANSWER: A mock-up ol a cost generator fbr the Campus is enclosed. The
enclosed mock-up allocates cost using two ntethods: one if sub-meters are placed on transtbnners,
and the other if sub-meters are placed on Switch Gear. IDOA will create one specifically for the
SCADA, if it is able to use that systern.
In the rnock-up, the "bill"' is populated first with infnrmation from the ldaho Power
Company bill; the hilling periocl date, the kWh used and the dollar amount. Readings are takcn
from the metcr databasc correspondirrg with the Power Company bill service period end date. The
data can be populated either manually or automated. For the Capitol Mall, IDOA uses "nretalink"
to populate an Excel spreadsheet fiom a SQL database. Sub panels related to common areas are
added to the per building readings. 'l'hese togethe'r create the "bill" lbr each INDF.X.
Readings at meters are typically logged every fifteen ( l5) rninutes. A typical electric meter
carr "hold" or rnainlain data tbr about two (2) months. should there be a connection to sen er issue.
For the Capitol Mall. IDOA's electric meter readings archive data goes back to 1992. The electric
data on the HPI SCADA database provided to IDOA went back to 2004.
Despite the "bill" produced for the Capitol Mall and mocked up in thc cncloscd
spreadsheet. facilities costs are allocated differently based on user type as fbllows:
State Agerrcy Users. The costs of state tacility use by state a*rrency users. including utility
costs, are paid through a combination of direct legislative appropriation to IDOA and a ratc paid
for use of the space by the using agenc)'established in the agency''s legislative appropriation. -lhe
IDOA appropriation pays its personnel costs, certain capital costs such as maintenance equipment
and vehicles" and routine maintenance costs such as elevator and fire system inspectiorrs and costs
in excess of agerrcy budget allocations. Agency budget allocations co!'er agency use of state
tacilities on a "full services" basis. Sirnilar to a fulI sen-"ices lease discussed below, agency users
do not incur costs other than their appropriated budget fur their routine use of a state tacility.
Certain costs specific to an agency. however, are paid using separate agency appropriated funds.
IDOA RESPONSE TO FIRST PRODUCTION REQUEST TO THE IDAHO DEPARTMENT OF
AMINISTRATION - 7
These agency specific costs include the costs of replacing carpets or remodelirlg space and are not
included withirr the appropriation to the agency for use of state space.
To develop the appropriated budget fbr agencies and the IDOA, IDOA tracks costs incurred
in operating the state facilities such as utilities, janitorial services and supplies, light bulb
replacement. landscaping. common area maintenance, and window cleaning. IDOA provides this
infonnation to the Division of Financial Management and the Legislative Services Office. Based
on this information, rental rates are included in agency budget requests for considcrati,on by the
legislature. Rents as appropriated are collectcd tiom state tenants by IDOA using its interaccount
transaction autliority discussed in the answer to Request No. 7.
Former HP Inc. Tenants. The costs paid by fonner HP Inc. tenants are govemed by the
leases negotiated between the tenant and HP Inc. as the fonner landlord as follorvs:
First Tcchttology fs6ls1'alCredit Ltnion (Building 2): The First Technology Federal Credit
Union Lease rvas originally a master lease fiir multiple HP Inc. properties. The [.ease was revised
during the purchase process only to separate it to a stand-alone lease serving the Boise site and the
tenns were not materially rnoditied. The base rent paid by the tenant is for a full services lease.
with the exception of after hours HVAC charges. ,Sce paragraph l(G). pp. l-2 of the Lcasc
Agreernent. Under a full services lease, tlre base rent is the only paynent a landlorcl receives fbr
all the costs or services idcrrtiflcd in the lease. Utilities are commonly within the base rent of a
full services lease and are included in the First Technology Federal Credit Union Lease base rent.
After hours HVAC charges arc additiorral rent and are allocated as a share of the actual costs
representing the square tbotage clf the leased prernises in relation to the square fbotage of the
building. Sc,c paragraph 9.p. 5 of the Lease Agreen:ent. The IDOA has not had a request by First
Technology Federal Credit Union related to after-hours use fbllorving IDOA's assumption ol'the
Lease.
Hcv'lattPeckurelEntcrpriseCompan.t'(Building2): 'l'heHPhrc.LeaseassumedbyIDOA
is a full senices lease and base rent covers the identified senices. including utilities. Sce
paragraph l2. p. -3. and Exhibit C of the [-ease: Sce also Second Amendment to Lease. paragraph
2(a) (lncreasing the annual rent to "cover estimated incremental power cosls.").
Entcrpri.sa Scr-r'ict:.s /,tCi (Building 4): -fhe HP Inc. Lease assumed by IDOA is a tirll
sen ices lease and base rcnt covers the identified serv'ices, including utilities. Scc paragraph 12. p.
3. and Exhibit C of the Lease.
IDOA RESPONSE TO FIRST PRODI"JCTION REQUEST TO THE IDAHO DEPARTMENT OF
AMINISTRATION. S
S.vkes Enterprises. Inc'orporatcd (Building 8): The HP Inc. Lease assumed by IDOA
ohligates the IDOA to provide Standard Tenant Services sct forth in paragraph5.2, p. l8 of the
Lease in exchange tbr the base rent. Starrdard Tenant Services inclr.rde electrical serv'ice, howevsr.
paragraph I 5.2(b) provides:
If Tenant consumes more electricity than 4 watts per usable square foot (excluding
lighting and air conditioning), Tenant shall pay the cost of such excess electricity
consumptit'rn (as deternrined by submeter installed at Tenant's cost or as reasonably
determined by Landlord) to Landlord as Additional Rent pursuant to Section 3.2(d)
above.
HP lnc. HP Inc.'s Lease contains provisions at paragraphs 5.1 and 6.6 concenring
allocation of costs related to Standard Tenant Services, including utilities. Following execution of
the Lease. the Idaho Power Company accounts fbr clectric service tcl the Canrpus were transferred
into the name of IDOA. The provisions of 6.6 have not been tbllowed firr electric billings. Instead.
HP Inc. and IDOA have infunnally agreed to allocate intcrim utility charges for electric service
based on square firotage until the Landlord Separation Work set forth in section 6.5(A) is cornplete.
This likely results in under-billing to HP Inc. because portions of the Campus billed to IDOA and
used in thc square footage allocation are unoccupied.
IDOA Contact: Keith Reynolds. Deputy Director. Department of Aclministration
208-3 3 2- I 8 I 2, Keith. Revnolds@.adm.idaho. gov
IDOA RESPONSE TO FIRST PRODUCTION REQUEST TO THE IDAHO DEPARTMENT OF
AMINISTRATION - C)
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REQUEST NO. 7: With respect to the Campus, ivill electricity costs be a separately
identified component on cach bill provided to non-state tenants? Will electricity costs be a
separately identified component on the bill provided to state agencies? Please provide a sample
bill fbr tenants at the Campus.
IDOA ANSWER: IDOA nianages use charges or rent differently for private tenants under
the leases assurned ffom HP Inc." the HP Inc. Lease. and for state agencies.
Assumcel Leascs'. As with urost comrnercial leases. IDOA does not bill private tenants for
monthly rent (base rent), which is due and paid by the tenant as provided in the Lease. For
example, paragraph 3.I of the Sykes Enterprises. lncorporated Lease provides that base rent is due
and payable to the landlord in advance of the first day of each calendar montli. Paragraph 3.6 of
this Lease states that all rent payments arc to be made to landlord as it directs.
For full services lease tenants rvhere no additional charges arc authorized by the Lease,
IDOA cannot bill the tenant firr such charges arrd pays those charges using the base rent paid by
the tenant or I[)OA's appropriation. This is the same process used by the Idaho Pubhc Utilities
Cunmission's l-ease. which is a full sen'ices lease. l'he Comrnission's fiscal statf rna-v be able to
provide additional infomration on how this process rvorks in practice.
For lenants where an additional charge related to certain uses is authorized. such a r:harge
is "additional rent." For exanrple, in the Sykes Enterprises. Incorporated Lease, clectric use is
generally covered under the base rent payment. hou'ever use by the tenant in excess of 4 watts per
usable square foot is identified as additiorral rent. Scc Lease paragraph 15.2(b). IDOA as landlord
is authorized under the Lease to use any reasonable rnethod to detennine the tenant's use of
electricity and would provide a notice of adclitional rent under the noticc provisions of Lease
paragraph 13.10 to the tenant address identitled in Article L So long as Sykes Enterprises,
Incorporated is the sole tenant of Building 8, IDOA could use the separate billing frorn Idaho
Power as a reasonable basis tbr the additional rent. If state agencies are using portions of Building
8. IDOA could use a SCADA reading or sub-meter as a reasonable basis fbr additional rent. Sub-
meters are specifically identified as a reasonable basis for additional rent related to excess
electricity use in paragraph l5.l(b) of the Lease. Additional rent fbr excess electricity is paid
uncler section 3.2(d) of the Lease and is paid with the next base rent paynent.
HP Inc. Lecsc'. As discussed in the answerto Request No. 10, the HP Inc. Lcase is not a
full senices lease. IDOA bills in arrears fbr utilities by utility type. The HP lnc. Lease includes
IDOA RESPONSE TO FIRST PRODLJCTION REQUEST TO THE IDAHO DEPARTMENT OF
AMINISTRATION - I2
provisions for "interim utilitl' payments" covering the period betrveen lease commencement and
separation of utilities at paragraph 6.6 of the Lease. As discussed in the answcr to Request No. 4.
the parties are infbrmally allocating electric charges billed to the Campus based upon square
footage until the electric use can be separated by sub-meter or SCADA system. Under Lease
paragraph i.8. HP Inc. can audit IDOA's allocation of costs.
Stcte Agencv Ltsers'. State agencies are not billed. As discussed in the answer to Request
No. 4. state agency use costs are allocated to either the IDOA appropriation or the agency
appropriation. Funds appropriated to agenc)'users are directly'deducted fiom the agenc!"s
operating fund in the treasury by interaccount transaction under the authority granted to IDOA in
Idaho Code section 67-5704. This process is subject to audit by the Legislative Services Office
whcn auditing an agency user or IDOA.
IDOA Contact: Keith Reynolds, Deputy Director, Deparlment of Administration
208-3 3 2- 1 8 I 2. Keith.Reynolds(gadm. idalro. gov
IDOA RESPONSE TO FIRST PRODUCTION REQLJEST TO THE IDAHO DEPARTMENT OF
AMINISTRATION. I3
REQUEST NO. l0: StafT understands tlre Campus is served by Idaho Porver, whcr
supplies prirnary service under Rate Schedule 19. Rate Schedule 19 has several components:
service charge, basic charge, demand charge (varies by season), on-peak demand charge, and
energy charges tbr on-peak, mid-peak u,rd o11'-peak usage (varies by season), Staff also
understands that HP Inc.'s Lease provides that IDOA only will bill HP Inc. fbr HP Inc.'s actual
costs. Horv will total costs of electricity be recovered for HP Inc.?
IDOA ANSWER: IIP Inc.'s Lease is not a typical full services lease and is complex. The
following discussion is intended to explairr how costs. including electrical costs are allocated in
the context of the complex Lease.
The Lease provides base rent tbr all of the covered tenant serv'ices and either direct payrnent
or allocation of other costs. Unlike a typical full services lease. H P Inc. undeftakcs certain repair
and nraintenance obligations. provides tor the security in its leased premises, is allowed to make
certain improvements and alteralions rvithout landlord approval. and is ar.rthorized to manage one
of the chilling and one of the boiling plants at the Campus. The base rent paid by HP Inc. under
the Lease reflects the lower costs transf'erred to thc landlord in this atypical leasc.
The HP Inc. Lease required utility separation and specifically authorizes Emon brand or
other sub-meters in satisfirction of the required scparation of clcctrical seruicc. Scc paragraph
6.5(AXvii) of the Lease. IDOA understands HP Inc.'s request to include paragraph 6.5(A) is to
establish processes tbr utility cost allocation in satisfaction of federalta.r larv requirernents that it
pay its orvn utility costs follorving the lease back of real properly it fbnnerly owned. HP Inc. has
detennined that separation using sub-rneters represents the actual costs fbr electric charges
accurately. HPIrrc.'suseoltheCampusdoesrrotdilferfiomotherusersinthetl'peolactivitl,or
hours of use.
IDOA also believes that the utility separation usin-e sub-rneters accurately' reflects HP Ine .'s
use of elcctric scrvicc. Altirough IDOA bclicves HP Inc. is not fully paying thc costs of electric
service prior to separation. this belief arises tiom the use of square footage to allocate costs and
not because HP Inc.'s use varics b,v time of da1' or scason. ,Scc Ansrvcr to Rcqucst No. 4. IDOA's
analysis of off-peak and rnid-pcak costs in the most recent ldaho Power Cornpany billing for the
Campus (cxclusive of Building 8) shows that cost diflbrence between 6ff:peak and mid-peak costs
is 4i 10 of one cent (.00.1235). representing approxinrately 4.1o/o ctf the total bill ($8517.81 of a
S193.275.71 monthly bill). This analysis confirms that sub-metering will produce accurate
IDOA RESPONSE TO FIRST PRODUCTION REQUEST TO THE IDAHO DEPARTMENT OIT
AMINISTRATION - I6
allocation sufficient to satislv IDOA and HP Inc.'s Lease as rvell as the Comnrission's stated
purposes.
Future variations in electric use are also addressed by the Lease. Lease paragraph 5.1(AX I )
provides the general language for utility costs and applies aller utility separation under Lease
paragraph 6.-5 is conrplete. This paragraph provides that IDOA shall contract clirectly with a utility
provider to the cxtent there is no separate meter. Paragraph 5.1(AX I ) further provides:
If 'l'enant's use of utilities is in excess of normal general of'fice occupancl' loads
arrd the Premises is not separately metered or submetered, Tenant shall separately
meter or sub-meter the Premises fbr such excessively used utility" at its sole cost
and expense.
Even if physical sub-meters are used at the CanTpus. this paragraph rvould allow IDOA's SCADA
system to be used to allocate electric use by time of day and season and produce records tied to
Rate Schedule l9 should HP lnc. use of the Campus change so as to use utilities in a manner in
excess of normal general office occupancy loads.
Lastly. the Lease dellnes "Nomtal Business Hours" as the period betr.veen 7:00 a.rn. and
6:00 p.m. on State of ldaho business days and between 8:00 a.m. and I :00 p.m. on Saturdays. This
definition is consistent rvith general office occupancy, including ldaho state agency use. The
Lease's ternrs concerning the provision of utilities onll' appll' to Normal Business l{ours. Sca
Lease paragraph 5.1(AXl). If HP lnc. changes its operations so that it is not consistent with
Nonnal Business Hours. the IDOA can notify HP Inc. that IDOA is not rcquired to provide utility
access tilr that operation and request an appropriate adjustment to the Lease tenms.
IDOA Contact: Keith Reynolds. Deputy Director, Department of Adrninistration
208-3 3 2- 1 8 I 2, Keith. Reynolds(qadm.idaho. gov
IDOA RESPONSE TO FIRST PRODLJCTION REQUEST TO THE IDAHO DEPARTMENT OF
AMINISTRATION - I7
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-19-09
IDAHO POWER COMPANY
ATTACHMENT 5
ldaho Power Company Twelfth Revised Sheet No. 19-4
Cancels
l.P.U.C. No. 29, Tariff No. 101 Eleventh Revised Sheet No. 19-4
SCHEDULE 19
LARGE POWER SERVICE
(Continued)
MONTHLY CHARGE (Continued)
PRIMARY SERVICE
IDAHO PUBLIC UTILITIES COMMISSIONApproved Effective
May 31,2018 June 1,2018
Per O.N. 34071
Diane M. Hanian Secretary
Non-summer
$299.00
$1 26
$4.47
nla
3.92130,
3.50s60
Non-summer
$299.00
$0.70
$4.34
nla
3.90290
3.48930
Service Charge, per month
Basic Charge, per kW of
Basic Load Capacity
Demand Charge, per kW of
Billing Demand
On-Peak Demand Charge, per kW of
On-Peak Billing Demand
Energy Charge, per kWh
On-Peak
Mid-Peak
Off-Peak
TRANSMISSION SERVICE
Service Charge, per month
Basic Charge, per kW of
Basic Load Capacity
Demand Charge, per kW of
Billing Demand
On-Peak Demand Charge, per kW of
On-Peak Billing Demand
Energy Charge, per kWh
On-Peak
Mid-Peak
Off-Peak
Summer
$299.00
$1.26
$6.03
$0.95
5.23130,
4.15990,
3.71170,
Summer
$299.00
$0.70
$5.85
$0.95
s.17190,
4.13070,
3.6875d
nla
nla
PAYMENT
The monthly bill for service supplied hereunder is payable upon receipt, and becomes past due
15 days from the date on which rendered.
IDAHO
lssued per Order No. 34071
Effective - June 1,2018
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC.E.1 8.08
IDAHO POWER COMPANY
ATTACHMENT 6
REQUEST NO. 8: With respecl to the Campus, has the IDOA entered into an Energy
Savings Perfirnnance Contract(s) as described in Idaho Code 5\ 67-571lD? If so. please provide
copies of any contract. If not. does IDOA intend to enter into any such contract? Please explain.
IDOA ANSWER: IDOA has not entered and does not anticipate entering an Energy
Saving Performanc.e Contract. The state has not had sufficient operating history with the Chinden
facilities to detennine if an Energy Savings Perfbrmance Contract would be beneficial.
Improvements will be rnade as rvork scope is identified and funds become available, ,uvithor,rt the
Iong-term financial obligation of a Pertbrmance Contract.
IDOA Contact: Jan Frew. Administrator, Division of Puhlic Works
208-332- I 9 I 2. Jan. [e-mail]
IDOA RESPONSE TO FIRST PRODUCTION REQUEST TO THE IDAHO DEPARTMENT OF
AMINISTRATION. I4
REQUEST NO. 9: In its preparation for state office occupancy in Building 2. has IDOA
installed. or does it intend to install. any energy efticiency measures in the near future? Please
explain.
IDOA ANSWER: AII improvements to Building 2 will be constructed according to
current building and energy codes. Significant areas of improvement include:
L Hundreds of fluorescent light fixtures that currently house Tl2 larnps will be
removed. New fixtures will be installed that utilize LED larnps.
2. New ceiling systcms will be installed in eighty percent (80%) of Building 2, at a
lower height than the current configuration. This will reduce tlie volume of space needing to be
conditioned.
-1. The existing roof will be replaced with a new single-ply roof and insulation system.
1. The Building HVAC system rvill be totally re-worked. with a large amount of
equiprnent being replaced with new. energy efficient equipment.
5. A lighting control system will be installed.
6. A Building Automation System will be installed that will allow efficient
programmirrg and monitoring of all building systems.
IDOA Contact: Jan Frew, Administrator, Division of Public Works
208-332- I 9 I 2" Jan. [e-mail]
IDOA RESPONSE TO FIRST PRODUCTION REQUESTTOTHE IDAHO DEPARTMENI"OF
AMINISTRATION . I5