20141222IPC Angell Direct.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OE THE APPLICATTON )oF PACTETCORP D/B/A ROCKY )
MOUNTAIN POWER AND TDAHO POWER ) CASE NO. IPC-E-14-41
CoMPANY FOR AN ORDER AUTHORTZTNG )
THE EXCHANGE OF CERTATN ) CASE NO. PAC-E-14-11
TRANSMISSION ASSETS. )
)
IDAHO POWER COMPANY
DIRECT TESTTMONY
OF
DAVID M. ANGELL
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o.
A.
O. Pl-ease state your name and business address.
A. My name is David Angell and my business
address is 1227 West Idaho Street, Boi-se, Idaho 83702.
O. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("Idaho
Power" or "Company") as the Planning Manager in the
Customer Operations Engineering and Constructj-on
Department.
University of Idaho, Moscow, Idaho, receiving a Bachelor of
Science Degree and Master of Engineering Degree in
Electrical Engineering, respectively. I have provj-ded
electrical engineering instruction for both the University
of Idaho and Boj-se State University. Most recently I
instructed power system analysis at Boise State University
during the 2009 spring semester.
Pl-ease describe your educational background.
I graduated in 1984 and l-986 from the
Please describe your work experience wj-thO.
Idaho Power.
A.From 1986 to L996, I was employed by Idaho
Power as an engineer j-n both communicatj-ons and protection
systems. In 1995, I became the Engi-neering Leader of
System Protectj-on and Communications. I hel-d this position
until 2004, when I transferred to Transmission and
Distribution Planning. During the fall of 2006, I accepted
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Idaho Power Company
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the positions of System Planning Leader and Manager of
Delivery Planning. I have been managing Idaho Power's load
research, interconnected-transmisslon system, sub-
transmi-ssion, and distrj-bution planning since 2006.
O. What is the purpose of your testimony in this
case?
A.My testimony in this case will provide an
overview of the Joint Purchase and Sale Agreement (*JPSA")
and the Joint Ownership and Operating Agreement ("JOOA"),
an overvi-ew of Idaho Power's current and proposed ownership
and capacity rights related to the assets at issue in this
case, and a description of the assets being acquired by
Idaho Power and the benefits associated with the exchange
of each asset.
O. What is the objective of the JPSA and the
JOOA?
A. Idaho Power and PacifiCorp (together, the
"Parties") have entered into the JPSA and JOOA to replace,
amend, or consolidate several agreements including the
Restated and Amended Transmission Facilities Agreement
("RATFA") and the Restated Transmission Services Agreement
(*RTSA-) (col-Iectively "Legacy Agreements")l with agreements
'l' The RATEA, RTSA, and Eirst Revised Agreement for Interconnectlon and
Transmission Services ("ITSA") are the primary agreements between the Parties.
There are a number of related agreements which support or are directly
connected to the RATEA, RTSA, and ITSA. The RATEAT RTSA, and ITSA and
remaj-ning agreements are collectively referred to as the "Legacy Agreements".
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Idaho Power Company
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that w111 meet the respective and mutual transmission
service needs of each Party through a comblnation of Open
Access Transmj-ssion Tariff ("OATT") service, real-locatj-on
of ownership interests in jolntly-owned facilities, and the
exchange of certain transmission facilities. Additionally,
the JPSA and JOOA j-nclude terms that appropriately address
the operation, maintenance, reliability, and technical
aspects associated with joint ownership. The Legacy
Agreements will be mutually terminated, amended, or
consolidated upon execution of the JPSA and JOOA and the
Parties anticipate makinq adjustments to their respective
Eederal Energy Regulatory Commi-ssion-approved transmission
formula rates.
o.How do the JPSA and JOOA meet the respective
and mutual transmisslon service needs of each Party?
A.The JPSA and JOOA will provi-de: (1)
PacifiCorp with 1,600 megawatts ("MW") of capacity across
Idaho Power's transmission system through a combination of
asset ownership and OATT service, (2) Idaho Power with
capacity on the existj-ng PacifiCorp 500 kil-ovolt ("kV"),
230 kV, 161 kV and 138 kV transmission system through an
asset ownership arrangement, and (3) a reallocation of the
existing joint ownership interests on the 345 kV and 230 kV
Jim Bridger transmi-ssion system ("Jim Bridger Transmission
System") to align wj-th the Parties' current operational
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Idaho Power Company
1 requirements. Additionally, the JPSA and JOOA will- include
2 provisions establishing the respective rights and
3 obligations of the Parties related to joint ownership,
4 operation of jointly-owned facj-1ities, and operational
5 business practices. The transaction does not create any new
6 avail-able transmission capacity.
7 Q. What are the Parties requesting in this case?
8 A. Under the JPSA and JOOA, the Partj-es desired
9 to exchange with one another certain jointly-owned and
10 whoI1y-owned equipment to provide each Party with
11 transmj-ssion capacity that better aligns with the current
L2 configuration of its transmission system and current
13 transmission and load service obligations, each of which
1,4 has changed since the Legacy Agreements were executed and
15 the jointly-owned and wholly-owned equipment were
76 originally constructed. Pursuant to Idaho Code S 67-328,
l7 an electric util-ity must obtain approval from the Idaho
18 Publ-ic Utilities Commissj-on ("Commission") before it sells
19 or transfers ownership in any generation, transmission, or
20 distribution p1ant. By detailing the benefits associated
2l with assets being exchanged through the JPSA and JOOA, ffiy
22 testimony will demonstrate the transaction is consistent
23 with the public interest.
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Idaho Power Company
1 Q. You indicated the JPSA and JOOA will- replace
2 Lhe Legacy Agreements. Please describe the agreements that
3 will be replaced.
4 A. The Legacy Agreements originated with the
5 construction of the Jim Bridger power plant ("Jim Bridger
6 Plant") and the resulting Jim Bridger Transmission System.
7 A detailed description of the Legacy Agreements can be
8 found in Ms. Lisa Grow's testimony. In general, the intent
9 of the Legacy Agreements was to move energy from the Jim
10 Bridger Plant to l-oad in the PacifiCorp West Balancing
11 Area. When Utah Power and Light and Pacific Power & Light
72 merged, incentive to move energy to serve Goshen area loads
13 was created. As explained in Ms. Grow's testimony, the
t4 Legacy Agreements were amended and restated over time.
15 O. Pl-ease provide an overview of the Parties'
76 existing wheeling rights.
77 A. Exhibit 2 details the existing wheeling rights
18 of each Party and the transmission facility areas they
79 cover. The RATEA covers the ownership, 2,400 MW capacity
20 allocation, and operation of the Jim Bridger Transmission
2t System which is composed of three transmission l-ines that
22 originate at the Jim Bridger Plant, near Rocks Springs,
23 Wyoming, and terminate at substations in eastern Idaho near
24 Pocatello and American Falls. The RTSA provides !,400 MW of
25 capacity rights to PacifiCorp across the Idaho Power
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Idaho Power Company
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transmission system from the eastern Idaho substatlons to a
substation near Jerome, Idaho and on to substatlons near La
Grande and Enterprise, Oregon.
o.Please provide an overview of the ownership
rights that will result from the JPSA and JOOA.
A.Exhibit 3 provides a representation of the new
ownership rights and their locations as a result of the
JPSA and JOOA. The reall-ocation of the Jim Bridger 345 kV
transmission system w111 result in one-third ownership
rights for Idaho Power and two-thirds ownership for
PacifiCorp across each of the three transmission 1J-nes,
whil-e Idaho Power's portion of the Jj-m Bridger 230 kV
substation and l1nes wil-l be transferred to PacifiCorp.
Bel-ow are additional- details of the major transmission
reallocation that are represented in Exhibit 3:
l-090 MW east-west transmission capacity on the
Borah and Kinport to Midpoint lines to PacifiCorp
410 MW east-west transmj-ssion capacity on the
Midpoint to Hemingway line to Idaho Power
700 MW west-east transmission capacity on the
Hemingway to Midpoint l-ine to Idaho Power
450 MII'I west-east transmission capacj-ty on the
Summer Lake to Hemingway line to Idaho Power
325 MW west-east transmission capacity on the
Wall-a Wal1a to Enterprise line to Idaho Power
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Idaho Power Company
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Further, ds presented in Exhibit 4, Idaho Power will
receive ownership in the Goshen and Antelope substations,
Antelope Scoville, and sections of the Antelope Goshen
and American Ealls - Malad transmission l-ines.
o.Idaho Code S 61-328 (3) states the Commission
must find that the transaction is consistent with the
public interest prlor to authorization of the transaction.
Please explain how the transfer of fdaho Power's assets to
PacifiCorp is in the public interest.
A.The majority of the assets being transferred
to PacifiCorp from Idaho Power are rel-ated to the
realignment of the Jim Bridger Transmission System while
most of the remainj,ng assets are rel-ated to the Borah West
transmj-ssion system. Idaho Power's receipt of capacity on
two of the three l-ines of Jim Bridger Transmission System,
il-l-ustrated on Exhibit 4 as the gray l-ines from Bridger to
the west, affords PacifiCorp with capacity on the remaining
transmission line, illustrated on Exhibit 5 as the yellow
l-ine from Bridger to the northwest. Similarly, as part of
the JPSA and JOOA, about 42 percent of Idaho Power's sofe
ownership in the Borah West transmission system will be
transferred to PacifiCorp. This transfer is demonstrated in
Exhibit 5 beginning at Borah. In both cases, the Legacy
Agreements provide PacifiCorp with these capacity rights
today and Idaho Power will continue to retain capacity in
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both transmission systems. Disposing of these assets
allows Idaho Power to acquire other assets that provide for
present and future l-oad service obJ-igations. Exhibit 5
detail-s the assets PacifiCorp wiII acquire and the
following chart summarizes the net book value assocj-ated
with those assets:
Assets Transferred to PacifiCorp Ilet Book
.Iim Bridger transmission system realignment $15,517,364
Borah West transmission system $26,661,044
Goshen-Jefferson-Big Grassy transmission $83,186
Hemingway substation realignment $991 ,442
Tota1 s43 ,265, 036
O. Please describe in detall the transmissj-on
facil-ities Idaho Power wiIl receive capacj-ty and ownership
in to facil-itate its service obligations as part of the
asset exchange.
A.Exhibit A of the JPSA provJ-des a detailed list
of the ownership percentages of each transmission line or
substation asset to be acquired by each Party, including
the existing ownership and the percentage of ownership
being transferred through the JPSA and JOOA. Simil-arly,
Exhibit C of the JOOA provides a detalled l-ist of the
existing percentage segment ownership interests,
directional- capacity al-l-ocation in MW, and the operator of
each transmission facility. Generally, Idaho Power will
recej-ve capacity and ownership from PacifiCorp where
ownership currentl-y does not exist in the Kinport - Goshen,
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Antelope - Goshen, Antelope Scovill-e, American FaIls
Ma1ad, Midpoint - Hemingwdy, Hemj-ngway - Summer Lake, and
Wall-a Wall-a Hurricane transmission Iines and the Goshen,
Antelope, Burns, Summer Lake, Walla Wa11a, Hurricane,
Jefferson, and Big Grassy substations.
o.You stated the JOOA includes provisions
establishing the respective rights and oblj-gations of the
Parties related to joint ownership and operation of
jointly-owned facilities, as weII as detailing the operator
of each transmission facility. Please describe the rol-e of
the operator with regard to these transmissi-on facilities.
A.The operator wil-1 supervise and perform the
physical operation and maj-ntenance of, interconnection to,
design of, capital upgrades and improvements to, repaj-r and
reconstruction of, security of, outage restoration of, and
retirement and decommj-ssj-oning of the transmi-ssion
facilities and common equipment for which they are
responsible in accordance with applicable governmental
requirements and reliability standards. Maintenance
renewals and replacements to the transmj-ssion facilities
are j-ncluded in the service for which the operator is
compensated. As a resul-t, the operator is responsible for
coordinating all requests for interconnection to any of the
jointly-owned transmj-ssion facilities. The requests will
be processed in a manner consistent with the operator's
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OATT and any governmental- requirements, maintaining
existing interconnection processes.
o.Please describe the acquisitJ-on of the Kinport
Goshen line and any related benefits.
A.The acquisition of ownership in the Kinport
Goshen transmission line, indicated on Exhibit 4 as the
Idaho Power Acquired Assets between the Goshen and Kinport
poj-nts, is part of the Jim Bridger Transmission System
realignment. As noted in the Application, there are three
345 kV transmission lines that connect the Jim Bridger
Plant to the Idaho Power and PaclfiCorp transmission
systems: the Jim Bridger - Goshen l-ine, the Jim Bridger
Populous - Borah line, and the Jim Bridger - Populous
Kinport line. Under the RATFA, PacifiCorp owns two-thirds
and Idaho Power owns one-third of the capacity of the
transmission l-ines. The Kinport Goshen transmission line
provides the connection of the Jim Bridger Goshen Iine to
the Idaho Power transmission system. The RATEA also
provides Idaho Power with transmission capacity rights on
the Kinport Goshen line. With the elimination of the
RATFA, Idaho Power requires ownership in the Kj-nport
Goshen line to transfer energy received at Goshen on the
Jim Bridger - Goshen line to the Idaho Power transmission
system at Kinport.
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O. What beneflts does the change in the Jim
Bridger Transmission System eastbound capacity provide?
A.The retention of at least 100 MW of Jim
Bridger Transmission System eastbound rights will ensure
that the sale of Jim Bridger generation can be sol-d as firm
energy by Idaho Power. More specifically, with eastbound
Jim Bridger Transmission System rights, if Idaho Power
sells energy at Jim Bridger to utilities, and a unit at Jim
Bridger trips offline, Idaho Power wil-l be abl-e to back up
the original sale with other Idaho Power generation,
maintaining the higher firm energy sales price. Without the
ability to back-up or firm the sale of Jim Bridger energy,
the sales price for this energy would be reduced
substantially.
O. Please describe the benefits associated with
the change in the Jim Bridger Transmission System westbound
capacity.
A.The reallocation of the Jim Bridger
Transmission System ownership to align with each owner's
capacity rights will allow each owner to delj-ver energy
during line outage conditions without having to rely on an
operating agreement. Operating agreements are subject to
interpretation and can become difficult to manage as
transmission configurations change and rel-iability
requJ-rements moderni ze .
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0. Pl-ease continue describing the benefits
rel-ated to the capacity and ownership of transmission lines
and substations that Idaho Power wiII acquire from
PacifiCorp.
A. Idaho Power will receive capacity and
ownership of the Antelope Goshen line and facilities at
the Goshen substation. Capacity on the Antelope - Goshen
line will provide a new source to reliabJ-y serve the
Blackfoot, Idaho area. In addition to improving
reliability, the Blackfoot area l-oad is forecasted to grow
in the next five to ten years. The present plan to meet
this growth incl-udes a new twenty-miIe line from the Brady
- Antelope 230 kV line to the Haven substation. The
Antelope Goshen Iine capaci-ty would provide increased
Ioad servlce rel-iability and operational flexibility for
the Blackfoot area, el-iminating the need for the Brady -
Antelope 230 kV l-ine at hal-f the cost of the present p1an.
O. Please describe the benefits rel-ated to the
Antelope Scovill-e l-ine and Antelope substation facilities
acquisition.
A.fdaho Power has an existing agreement wlth
PacifiCorp for capacity through the Antelope substation to
serve a single Idaho Power customer via the Scoville
substation. As part of this transaction, Idaho Power wil-I
acquire assets at the Antelope substation, converting an
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outdated legacy agreement to asset ownership and
eliminating the need to cross PacifiCorp's assets to serve
a single Idaho Power customer.
o.What are the benefits related to capacity on
the American Eal-Is - Malad l-ine?
A.As shown on Exhibit 4 in gray as an Idaho
Power Acquired Asset, the Ameri-can Ealls - Ma1ad l-ine
travels south from American Falls to Mal-ad through the
Arbon Val1ey. Idaho Power currently has capacity
Iimj-tations in the Arbon Valley area due to voltage
constraints and has had to quote customers expensi-ve
distribution upgrade requirements for l-oad requests, grant
load requests for significantly less than desj-red, or
simply deny load requests. The Company has al-so
experienced low voltage issues on the distribution feeder
due to the distance between the source substation and the
Arbon Va11ey, resulting in the rebuil-d of sectj-ons of the
feeder. Additional distribution upgrades woul-d be requl-red
in the future as existing customer l-oad growth j-ncreases.
This would result in costly upgrades due to the length of
the distributj-on feeder that typically requires multiple
miles of rebuild. However, ownership in the American Ea11s
- Malad line will- provide an alternative to rebuilding the
feeder at nearly half the cost of a distribution rebui1d.
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Please describe the benefits related to the
Midpoint - Hemingway acquisition.
A.As part of the exchange, ldaho Power will-
acquire 410 MW of Midpoint - Hemingway westbound capacity
("Midpoj-nt West"). The acquisition of westbound capacity on
this 500 kV l-ine, identified on Exhibit 4 in red with gray
outline between the Hemingway and Midpoint locations, will
help to relieve Midpoint West transmission path constraints
on Idaho Power's transmission system. When factoring in
Idaho Power's generation in eastern Idaho, Wyoming, and
Nevada, east-side power purchases, and Pacifj-Corp's rights
to transfer 400 MW across Idaho Power's transmission
system, the Midpoint West path currently is oversubscribed
by more than 150 MW with long-term commitments of
conditional firm energy. This oversubscription of
conditional firm energy limits Idaho Power's ability to
purchase energy from the eastern side of the Western
Interconnect. And, locating resources on the eastern side
of the ldaho Power system has become problematj-c due to the
substantial amount of new transmission investment required
to ful1y integrate a new resource into Idaho Power's
transmission system.
Idaho Power will also receive 700 MW of Hemingway -
Midpoint eastbound capacity. This capacity will greatly
j-ncrease Idaho Power's resource f lexibil-ity in the spring
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18 project (*B2H"). When completed, B2H will increase the
and earl-y summer. During spring run-off, the supply of
water is very high, weather i-s moderate, and resulti-ng
loads are Iight. Throughout spring, conditions regularly
exist where transfers from the Northwest into Idaho Power's
system, coupled with generation out of the Hells Canyon
complex, can substantially exceed Idaho Power's west side
l-oad. In these cases, eastbound capacity is needed across
Midpoint West path to source southern and eastern load and
reduce thermal coal generation in the east and serve load
with l-ow-cost hydro power from the northwest. With the
acquisition of Hemingway - Midpoint eastbound capacity,
this constraint will be al-leviated. Near-term benefits
also incl-ude increased maj-ntenance window flexibil-ity for
Midpoint West transmissi-on l-ines and other path equipment.
Eurthermore, the Hemingway - Midpoint eastbound
capacity wil-1 be necessary to completely and economically
integrate the Boardman - Hemingway 500 kV transmission
amount of power that Idaho Power can purchase from the
northwest by 500 MW during spring and sunrmer months. Given
today's Midpoint West eastbound capacity constraints, dD
additional 500 MW would exacerbate current problems and
l-imit the economic efficiency of the B2H line. Acquiring
this Hemingway - Midpoint capacity today will increase the
economic efficiency of Idaho Power's system, increase the
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I operational flexibility to maintain equipment now, and will
2 solve a future economj-c efficiency problem that would
3 otherwise appear with the B2H addition.
O. What are the benefits related to capacity on
5 the Hemingway - Summer Lake line?
A. Duri-ng peak summer l-oad months, Idaho Power
7 l-ooks to the Mid-C market to obtain additional resources.
8 These resources are brought in over intertj-es that make up
9 the Northwest-Idaho path. This path consists of tie points
10 with the Balancing Areas of Avista, PacifiCorp, and the
11 Bonneville Power Administration ("Bonneville"). During the
72 summer months, Idaho Power has allocated capacity on the
13 ti-es with Avista at Lolo or the combined ti-es wlth
L4 PacifiCorp at either Enterprise or Hemingway/l,tidpolnt to
15 meet load servj-ce needs. The tie to Bonneville is fu11y
76 subscribed.
71 In order to consider the resource a "network
18 resource" and util-ize network transmission on ldaho Power's
L9 system, the network customer (in this case, Idaho Power's
20 Load Serving Operations) must obtain firm transmission from
2I the Mid-C market to the Idaho Power intertie borders.
22 fdaho Power is unable to obtain firm transmission from the
23 Mid-C market to the Enterprise point during the summer
24 months as there is no firm transfer capability available on
25 PacifiCorp's transmj-ssion system for that path. The
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Hemingway - Summer Lake line became avail-able for eastbound
scheduling in 20L2. Since then, Idaho Power has reserved
over 200,000 megawatt-hours for Idaho retail load service.
Idaho Power projects increased future use of this
transmission path. As a result, Idaho Power has l-ooked to
the 500 kV connection at Hemingway/Midpoint as firm
capacity does exist and is available at that intertie.
Ownership in the Hemingway - Summer Lake line, identlfied
on Exhibit 4 as the red line with a gray outline between
the Hemj-ngway and Summer Lake l-ocations combined with
acquisition of facilities in the Burns and Summer Lake
substations, provi-des the opportunity to transact business
with Bonneville at Summer Lake and reduce Idaho Power's
transmission expenses. While the overall Northwest-Idaho
capaci-ty does not increase, it will provide Idaho Power the
opportunity to use more capacity on a firm basis for
resources because the firm capacity from the market can be
procured.
O. Please describe the benefits related to the
Wal-Ia Walla Hurricane transmission 1i-ne and substation
facil-ities acqulsition.
A.Currently, Idaho Power must whee1 across
Avista's, Bonneville's, or PacifiCorp's system to access
northwest energy markets. In terms of summer capacity,
Avista controls 340 MW of capacj-ty, Bonnevill-e controls 350
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MW of capacity, and PacifiCorp controls 510 MW of capacity.
Utilizing Pacifj-Corp's 510 MW of capacity generally
requires a Bonneville transmission wheeling expense,
resulting in higher transmission costs. Ownership of the
WaIla Wal1a - Hurrj-cane lj-ne, along with ownership of the
Hemingway - Summer Lake line, affords Idaho Power a
significant increase in the amount of capacity in the
Idaho-Northwest allocation.
The capacity on the Wal1a Wa11a - Hurricane line
will- also support opportunities for line upgrades in the
Idaho-Northwest that Idaho Power would not otherwi-se have
been abl-e to pursue. Upgrades on the Idaho-Northwest path
woul-d increase line ratings and add operational flexibility
at the HeIIs Canyon power pIant. Acquiring capacity on the
line supports participation in a new Walla Walla to McNary
transmission lj-ne further connecting Idaho Power to
Bonneville at the McNary substation and providing for
greater firm transmission access to the Mid-C market
without transmission wheeling expenses.
o.What are the benefits related to ownershj-p of
facilities at the Jefferson and Big Grassy substations?
A.Joint ownership in facil-ities at Jefferson and
Big Grassy wilJ- provide the ability to j-mport power while
also allowing for the conversion of antiquated legacy
agreements into a new operating agreement that better
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aligns with the Parties' current configuration of their
respective transmission systems and current load
obligations.
O. What is the net book value of the transmission
lines and substations Idaho Power will acquire?
A. The net book value of the assets Idaho Power
wiII receive from PacifiCorp is approximately $43,61'1,898.
O. Please provide the net book value details that
support the benefits assocj,ated with the acquisitlon of the
transmj-ssion lines and substations in the categories
described above.
A. The following chart details the net book value
of the assets as categorized above.
Assets Received from PacifiCorp Net Book
Jim Bridger transmission system
real-ignment
$L2,858 ,202
Antelope-Goshen line, Goshen substation $1,508,864
Antelope-Scovill-e 1ine, Antelope $323,060
American Falls-Malad line $72,762
Midpoint-Hemingway l-ine, Hemi-ngway
substation realignment
$10,765,168
Hemi-ngway-Summer Lake line, Burns and
Summer Lake substations
$12,284 ,740
Wall-a Walla - Hurricane line, Hurri-cane
and Wall-a Wal-l-a substations $4,678,1!7
Jefferson e Biq Grassv substations $1,186,990
Tota].$43,617,898
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book value
PacifiCorp?
does the net
receive from
assets Idaho
book val-ue
PacifiCorp
Power will
of the assets
compare to the net
transfer to
How
will
of the
ANGELL, DI 19
Idaho Power Company
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A. Although the net book values are subject to a
true-up adjustment fol-l-owing the closing of the exchange,
the estimated net book value of the assets Idaho Power wil-I
transfer to PacifiCorp j-s approximately $43,265,036, nearly
equal to the net book value of the assets Idaho Power wil-l-
receive, $43, 61,7, 898.
O. Does this concl-ude your testimony?
A. Yes, it does.
ANGELL, DI 20
Idaho Power Company
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28
STATE OE IDAHO
County of Ada
ATTESTATION OE.TESTII,!OI[I
SS.
I, David M. Ange11, having been duly sworn to
testify truthfully, and based upon my personal knowledge,
state the following:
I am employed by Idaho Power Company as the Planning
Manager in the Customer Operations Engineering and
Construction Department and am competent to be a witness in
this proceeding.
I declare under penalty of perjury of the l-aws of
the state of Idaho that the foregoing pre-fil-ed testimony
and exhibits are true and correct to the best of my
inf ormati-on and belief .
DATED this 19th day of December, 2074
SUBSCRTBED AND
December, 2074.
SWORN to before me this 19th day of
Residins atz $han, a6lalwMy commission expirei; !F')D -eO
ANGELL, DI 27
Idaho Power Company
David M. Angell
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
GASE NO. IPC-E-14-41
CASE NO. PAC-E-14-11
ANGELL, DI
TESTIMONY
EXHIBIT NO.2
Exhibit No. 2
Case No.IPC-E-14-4.1
Case No. PAC-E-14-11
D. Angell, IPC
Page 1 of1
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E.1&41
GASE NO. PAC-E-14-11
ANGELL, DI
TESTIMONY
EXHIBIT NO.3
Exhibit No. 3
Case No. IPC-E-14-41
Case No. PAC-E-14-11
D. Angell, IPC
Page 1 of1
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG-E-14-41
GASE NO. PAC-E-14-11
ANGELL, DI
TESTIMONY
EXHIBIT NO.4
Exhibit No.4
Case No. IPC-E-1441
Case No. PAC-E-14-11
D. Angell, IPC
Page 1 ofl
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IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-14-41
GASE NO. PAC-E-14-11
ANGELL, DI
TESTIMONY
EXHIBIT NO.5
Exhibit No. 5
Case No. IPC-E-14-41
Case No. PAC-E-14-11
D. Angell, IPC
Page 1 of 1oEx
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