20150422Comments.pdf

DAPHNE HUANG I.. JI. :' , ,
DEPUTY ATTORNEY GENERAL -rr r . nr
IDAHO PUBLIC UTILITIES COMMISSION t1'" 1i;,, ?7- i'll r''; u I
PO BOX 83720
BOISE, IDAHO 93720-0074 ., , ,' ,-,,
[phone] i;"-'
IDAHO BAR NO. 8370
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACTFTCORP DBA ROCKY MOUNTATN ) CASE NOS. rPC-E-14-41
POWER AND rDAHO POWER COMPANY FOR ) PAC-E-14-u
AN ORDER AUTHORIZING THE EXCHANGE )
OF CERTAIN TRANSMISSION ASSETS ) COMMENTS OF THE) coMMrssloN srAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Daphne Huang, Deputy Attorney General, and in response to the Notice of
Modified Procedure issued in Order No. 33231, submits the following comments.
BACKGROUND
On December 19, 2ll4,Idaho Power Company (Idaho Power) and PacifiCorp dba Rocky
Mountain Power and Pacific Power (collectively "PacifiCorp") (together, the ooParties" or
singularly the "Party") filed a joint Application asking the Commission to approve the exchange
of certain transmission assets between the Parties pursuant to Idaho Code $ 6l-328.
Idaho Code $ 6l-328 establishes that an electric utility must obtain approval from the
Commission before it sells or transfers ownership in any generation, transmission, or distribution
plant. Section 61-328 provides the Commission with authority to authorize the sale or transfer of
ownership according to the following: "Before authorizing the transaction, the public utilities
commission shall find: (a) That the transaction is consistent with the public interest; (b) That the
STAFF COMMENTS APRIL 22,2015
cost of and rates for supplying service will not be increased by reason of such transaction; and
(c) That the applicant for such acquisition or transfer has the bonafide intent and financial ability
to operate and maintain said property in the public service." Idaho Code $ 61-328(3). The
Parties acknowledge that the Commission has authority over this matter pursuant to Idaho Code
$ 61-328 (transfer of utility assets). See Application at 1.
On January 13,2015, the Commission entered a Notice of Application, Notice of
Intervention Deadline, and Order granting the Petition to Intervene filed on January 6,2015,by
the Industrial Customers of Idaho Power. The Department of Energy and Federal Executive
Agencies filed a Petition to Intervene on January 27,2015, but has since filed a Notice to
Withdraw its Petition to Intervene. Rule 68, IDAPA 31.01.068. The remaining Parties
informally conferred and agreed to a schedule for processing this case. The Notice of Modified
Procedure was issued on February I 8, 2015 establishing the schedule.
STAFF REVIEW
In response to the Parties'requests, Staff comments address the following issues: (l) the
transfer of assets; (2) joint agreements; (3) reliability and operational benefits; (4) avoided
capital investments; (5) transmission capacity improvements; (6) financial considerations; and
(7) reporting.
1. Transfer of Assets
On October 24,2014,Idaho Power and PacifiCorp entered into a Joint Purchase and Sale
Agreement (JPSA) and a Joint Ownership and Operating Agreement (JOOA) in order to
exchange transmission assets and ownership interests in jointly owned assets. The proposed
asset transfers are valuedl at approximately $43 million for each Party, subject to a true-up
adjustment following the closing date for certain upgrades placed into service and certain
equipment removed from service. See Application at 13. The transmission facilities that are part
of the Transaction are located in southwestern Wyoming, southern Idaho, eastern Oregon, and
southeastern Washington.
The Parties are required to obtain approval from the Federal Energy Regulatory
Commission (FERC, see Docket ECl5-54-000) and State Utility Commissions for each state in
I Based on the net book value of the assets as of December 31,2014.
STAFF COMMENTS APRIL 22,2015
which they operate. Idaho Power must obtain approval from the Public Utility Commission of
Oregon and the Idaho Public Utilities Commission. PacifiCorp must obtain approval from these
two states plus the Wyoming Public Service Commission, the Washington Utilities and
Transportation Commission, and the California Public Utilities Commission, and file a report
with the Utah Public Service Commission.
A list of the transmission assets and joint ownership interests transferred, along with a list
of specified upgrades, is presented in Exhibits A and B of the JPSA.2 Proposed ownership
interests and directional capacity and percentage allocations are presented in Exhibit C of the
JPSA. One of the impacts from the proposed transfer agreements includes a reallocation of
transmission assets associated with the Jim Bridger plant in Wyoming. The reallocation of the
Jim Bridger 345 kV transmission system would result in one-third (1/3) ownership rights for
Idaho Power and two-thirds (2/3) ownership for PacifiCorp across each of the three (3) Jim
Bridger transmission lines. Also, Idaho Power's portion of the Jim Bridger 230 kV substation
and lines would be transferred to PacifiCorp. See Application, DI Angell at 6, lines 8-13.
Details of additional major transmission reallocation include:3
o 1090 megawatt (MW) east-west transmission capacity on the Borah and Kinpoft -
Midpoint lines to PacifiCorp;
o 410 MW east-west transmission capacity on the Midpoint - Hemingway line to Idaho
Power;
o 700 MW west-east transmission capacity on the Hemingway - Midpoint line to Idaho
Power;
o 450 MW west-east transmission capacity on the Summer Lake - Hemingway line to
Idaho Power;
c 325 MW west-east transmission capacity on the Walla Walla - Enterprise line to
Idaho Power;and,
. ownership of Goshen and Antelope substations, Antelope Scoville, and sections of
the Antelope - Goshen and American Falls - Malad Transmission Lines to Idaho
Power.
2 An updated list of the Parties' Common Equipment that reflects any changes in the Common Equipment between
the Execution Date and the Effective Date shall be mutually agreed to by the Parties pursuant to the JPSA and the
updated list shall replace the above list effective as ofthe Effective Date.
3 See Application, DI Angel at 6, lines 16-25; at7.
STAFF COMMENTS APRIL 22,2015
2. Joint Agreements
Over the past 40 years, the Parties have entered into a number of agreements (generally
referred to as "Legacy Agreements") through which they jointly own and operate the Jim Bridger
power plant and associated transmission assets. These Legacy Agreements include, but are not
limited to: the Restated Transmission Service Agreement (RTSA); the Restated and Amended
Transmission Facilities Agreement (RATFA); and, the Interconnection and Transmission Service
Agreement (ITSA). One of the purposes of these Legacy Transmission Agreements is to move
energy from the Jim Bridger plant in Wyoming to PacifiCorp's "West Balancing Area" in
Oregon, Washington, and California. See Applic ation at 2-3.
The Parties have entered into a JPSA and a JOOA which, if approved by the
Commission, will replace approximately fourteen (la) Legacy Agreements, and amend and
consolidate three (3) other Legacy Agreements with current federal Open Access Transmission
Tariff (OATT) service and ownership. See Application at 8 and Attachment A.
The Parties assert the two new agreements would:
o be more consistent with current regulatory requirements than the Legacy Agreements
which use antiquated language and practices regarding transmission service. See
Application at4-5.
o "[c]onsolidate and modernizethe ownership and operational provisions of the Legacy
Agreements into a single agreement, the JOOA." See Application at 8.
. have more operational flexibility, thus improving reliability. See Application at 8.
o allow the Parties to "more efficiently operate the transmission system consistent with
current regulatory requirements." See Application at 8.
. allow the Parties to "more effectively manage required system upgrades and serve
expected load growth." See Application at 8.
Staff analysis generally supports the Parties' conclusions regarding the benefits of JPSA
and JOOA. These two new agreements would provide Idaho Power with capacity on the existing
PacifiCorp 500 kV, 230 kV, 16l kV and 138 kV transmission system. PacifiCorp would have
1,600 MW of capacity across Idaho Power's transmission system through a combination of asset
ownership (1090 MW) and Idaho Power OATT service (510 MW). Also these new agreements
would reallocate the existing joint ownership interests for both Parties on the Jim Bridger
transmission system. Staff believes the transaction is consistent with the public interest.
STAFF COMMENTS APRTL 22,2015
3. Reliability and Operational Benefits
Staff evaluated the benefits of the JPSA and JOOA in the context of reliability and
operation requirements established by FERC, the North American Electric Reliability
Corporation QIIERC), the Westem Electric Coordinating Council (WECC), and the Peak
Reliability Coordinator. Staff perceives significant improved reliability benefits due to the
reallocation of the transmission assets associated with the Jim Bridger power plant including an
enhanced ability to allow each Party to deliver energy during line outage conditions. For
example, following the asset reallocation, Idaho Power would obtain additional capacity in
constrained areas of the system, achieve more efficient use of the transmission system by native
load and third party customers, and acquire additional assets for local load service in eastern
Idaho (i.e., the Blackfoot area). PacifiCorp would obtain firm point-to-point transmission service
in accordance with Idaho Power's OATT, which would ensure PacifiCorp has a pro rata share of
the full northwest delivery capability during outage conditions.
The exchange would improve alignment with Idaho Power's current operational
requirements, and reduce the associated transmission expenses. Examples provided include, but
are not limited to the following:
Hemingway - Summer Lake: since 2012, "Idaho Power has reserved over 200,000
megawatt-hours for Idaho retail load service" (on the Hemingway - Summer Lake
line), and "Idaho Power projects increased future-use of this transmission path....
Ownership in the Hemingway - Summer Lake line...combined with acquisition of
facilities in the Burns and Summer Lake substations, provides the opportunity
to...reduce Idaho Power's transmission expenses." See Application, DI Angell at 17 .
Hemingway - Midpoint westbound capacity:a would help relieve Midpoint West
transmission path constraints on Idaho Power's transmission system, currently
estimated to be oversubscribed by 150 MW. See Application, DI Angell at 14, lines
l3-14.
a Hemingway - Midpoint eastbound capacity alleviates an internal transmission constraint for Idaho Power.
Second Response to IPUC Staff Production Request No. 38 at 7.
STAFF COMMENTS APRIL 22,2015
The asset exchange would improve access to adjacent transmission and generation assets
including additional resources during peak summer load months from the Mid-C market,5 while
eliminating some of the additional wheeling charges Idaho Power is subject to today.
PacifiCorp cites increased flexibility in the selection of resources to utilize the 1600 MW
of east-to-west transmission rights. Additional operational benefits are that PacifiCorp would
gain firm delivery rights to deliver power to the Bonneville Power Administration's La Grande
substation, which in turn would improve PacifiCorp's ability to deliver power from the Jim
Bridger power plant and other PacifiCorp East resources to meet its loads in PacifiCorp West.
Finally, PacifiCorp would gain additional rights to make firm power deliveries to PacifiCorp
West during line outage conditions and would gain more flexibility to meet its Goshen loads
with firm service.
The proposed JPSA would also increase dynamic services, including dynamic transfers,
for PacifiCorp from 200 MW to 400 MW. Dynamic transfers are firm energy transfers that can
be scheduled using a shortened time frame (within the hour) and for intervals as briefly as four
seconds. Dynamic transfers produce benefits for participants by more effectively stabilizing
electric load within the hour, increasing the pool of available energy services and reducing the
cost of integrating renewable energy into energy delivery. PacifiCorp further states that the asset
exchange would increase both transmission capacity utilization and the pool of resources
available for dispatch under the energy imbalance market (EIM). See Response to PacifiCorp
Production RequestNo. 18, McAllister at79.
4. Avoided Capital Investments
The asset transfer would benefit the customers of both Parties by reducing or avoiding
capital investment in transmission assets. If it is beneficial to ratepayers, Staff believes there is
value in establishing joint ownership of transmission assets to ensure reliability so that
significant investments in new transmission to simply comply with reliability requirements are
avoided (e.g., those associated with contingency analysis).
Avoided transmission capital investments that would otherwise be required to comply
with reliability and load growth requirements according to Idaho Power include:
s See Application DI Angell at 16.
STAFF COMMENTS APRIL 22,2015
. Antelope - Goshen Transmission Line to Idaho Power: provides load service
reliability and operational flexibility for the Blackfoot area, eliminating the need for
the tap of the Brady - Antelope 230 kV line at half the cost of the present plan. See
Correction to DI Angell at 12.
o American Falls - Malad Transmission Line to Idaho Power: provides an alternative
to rebuilding the Arbon Valley feeder at "nearly half the cost of a distribution
rebuild." See Correction to DI Angell at 13.
. Brady - Antelope 230 kV Transmission Line: the tap to the Haven substation and the
upgrade of the distribution feeder that presently serves the Arbon Valley customers
will no longer be needed.
Staff is concerned about PacifiCorp's capital investments that may be necessary to
provide reliable service and accommodate load growth to the PacifiCorp service area. For
example, Staff Production Request No. 6 to PacifiCorp asked, "What future anticipated projects,
including capital, maintenance, and operational, will no longer be needed as a result of this
transfer of assets?" PacifiCorp's response was, "There would be no changes to future anticipated
projects for PacifiCorp's capital l0-year plan, maintenance, and operations as a result of this
asset transfer." However, in PacifiCorp's response to the Industrial Customers of Idaho (ICP)
Production Request No. 3, Confidential Attachment}, tab "Transmission Altemative Costs,"
PacifiCorp indicated that substantial capital costs would be incurred in order to provide reliable
service and accommodate future load growth if the asset exchange was not implemented.
Regardless, Staff believes that substantial capital costs would be necessary to provide
reliable service and accommodate future load growth to a PacifiCorp service area if the
transmission asset exchange was not implemented. See Staff Confidential Attachment B. Staff
identifies this as one of the benefits from the proposed transfer of assets between the Parties.
5. Transmission Capacity Improvements
Staff evaluated the transfer of assets and planned improvements, given the JPSA. Staff
concurs with the Parties' assertions that the transfer of assets alone would not create any new
available transmission capacity. However, Staff believes that the planned improvemenls under
the agreements would result in transmission capacity improvements.
STAFF COMMENTS APRIL 22,2015
The JPSA requires Idaho Power to be responsible for upgrades necessary to provide
PacifiCorp with 510 MW of long term firm point-to-point transmission service on Idaho Power's
transmission system. See Application, JPSA at27, Section 2.9(b)(xiv). To comply with the
terms of the JPSA Idaho Power must upgrade their 230 kV transmission system west of
Midpoint substation. These upgrades6 would increase the capacity of the Idaho Power Midpoint
West transmission path rating from 1027 MW to 1300 MW. Under the JPSA, the Parties agree
that these planned improvements would be subject to a true-up adjustment following the closing
date. See Applicationat 13.
The Parties have identified additional improvements and upgrades that are planned for
the acquired assets between 2014 and2016. According to the Parties, the cost of these
improvements and upgrades are as follows:
See Application, JPSA, Schedules 1.1(e) and Ll(f).
Other examples of transmission capacity improvements that would result from Idaho
Power upgrades include:
o Replacing the Borah series capacitor would increase the total rating of the line from
l0l7 MW to 1229 MW.
o Replacing the Kinport series capacitor would increase the total rating of the line from
892 MW to 1235 MW.
o Various improvements to the Goshen - Jefferson segment would increase the rating
of the line from 143 MW to 254 MW bidirectional.
Staff will review the upgrades listed in the JPSA in more detail during future general rate
cases to ensure they comport with the asset transfer agreements and are prudent investments that
benefit Idaho ratepayers.
u The 230 kV upgrades to be completed by Idaho Power are: (l) install a23}ll38 kV, 300 MVA transformer at the
Bowmont substation and (2) replace two 230 kV series capacitor banks at the Midpoint substation. See Application,
JPSA, Schedule 1.1(k).
Partv 20t4 2015 2016 Total
ldaho Power 5 s,gtt,zgq s 4,199,000 s 23,280,000 S Eg,zgo,ooo
PacifiCorp S 6,24s,538 5 2,403,734 S r,ooo,ooo 5 g,oqs,otz
STAFF COMMENTS APRIL 22,2015
6. Financial Considerations
The Parties believe the asset exchange "benefits both Parties and is in the best interest of
both Parties' customers." See Application at 9. Further, the Parties request a finding by the
Commission that "the costs of and rates of existing electric service in the state of Idaho will not
be increased by reason of' the asset exchange. See Application at I 1.
In support of these assertions, the Parties cite the following:
o Adoption of the JPSA and JOOA would result in a modification of the inputs within
the OATT formula rate that more accurately reflects Idaho Power's cost of service,
benefitting Idaho Power's retail customers. See Application, DI Grow at 16-1.
. PacifiCorp's customers would gain the benefits from the asset exchange "in a manner
that is financially neutral to retail customers:" See Application Duvall DI at2-3.
Staff agrees with the Parties and believes the retail rates of existing service in Idaho
would not be increased by the transmission asset exchange based upon the following
considerations:
o The Parties have not proposed to raise retail rates as a result of the proposed asset
exchange. The projected investments, expenses, and revenue credits, as discussed in
other sections of these comments, support this assertion. Because the asset transfer is
essentially equal, rates should not change due to a change in the value of the Parties'
assets. Also the Panies assert, and Staff believes, that the maintenance and operation
expenses before and after the transfer would be similar.
o The assets exchanged will change ownership at their respective net book values, and
their respective book values are estimated to be similar, therefore no acquisition
premium would be paid or included in rates.
a. Current and Projected Operation & Maintenance Expenses
Both Idaho Power's and PacifiCorp's current and projected operation and maintenance
expenses would be similar. The Parties state that the ongoing expenses would "be similar to
expenses incurred today." See Application at 13. Idaho Power provided a comparison of current
and proposed monthly O&M expenses, as requested in Staff s Production Request Nos. 1 and2.
The O&M expenses would be similar for PacifiCorp as well.
9STAFF COMMENTS APRIL 22,2015
b. Financial Gains and Losses Associated with the Transaction
According to the Production Request responses from both companies, there would be no
financial gain or loss associated with the asset transfer. The transaction has been structured to
satisfy the requirements of a like-kind exchange. Each of the transfers necessary to complete the
exchange is part of an integrated, interdependent, mutual and reciprocal plan intended to
effectuate a tax-deferred exchange by PacifiCorp and Idaho Power of like-kind properties
pursuant to and in accordance with the provisions of Section 103 1, from the United States
Treasury Regulations and Internal Revenue Code. The Parties propose to purchase and sell
assets with nearly equivalent net book values. There would be a payment from Idaho Power
Company to PacifiCorp at closing, to level the value of the transaction for both Parties. Staff
believes this payment would be a nominal amount. There would be a true-up adjustment for the
final net book values not later than 180 days after closing.
c. Financial Benefits to Idaho Power Company and its Retail Customers
Idaho Power's retail customers would see a significant financial benefit from the
termination of the various historical legacy agreements (RATFA, RTSA, and ITSA) under the
JPSA and JOOA. According to Grow's testimony (Grow Direct at 18, lines l1-14), Idaho
Power's Idaho jurisdictional revenue requirement would be reduced by approximately $55.9
million over a ten-year period, on a present-value basis. This reduction would stem from the
change in Idaho Power's OATT tariff as a result of the termination of the Legacy Agreements.
That is, the increase in Idaho Power's OATT rates due to the termination of the Legacy
Agreements would lead to higher transmission revenue, which would serve as a revenue credit to
retail customer rates. This increase in transmission revenue credit is one of the main drivers of
the financial benefit derived from the retirements of the Legacy Agreements. See Application,
Grow at 18, lines l8-23.
The change to the Idaho Power OATT rates due to the retirement of the Legacy
Agreements is described using the following two equations.T Equation I shows how the loads
and revenues are treated in the Idaho Power formula rate and Equation 2 shows the formula rate
impacts following the termination of the agreements.
? Equation I and Equation2 are greatly simplified representations of the Idaho Power federal OATT formula rate
and the approximate reductions in transmission tariff rates due to the handling of the Legacy Agreements' load and
revenue.
STAFF COMMENTS l0 APRIL 22,2015
Equation l: Formula OATT Ratewith Legacy Agreement Load and Revenue Credits
Revenue Requirement - Legacy Contract Revenue Credit
Total Load + Legacy Contract Load
Equation 2: Formula OATT Rate without Legacy Agreement Load and Revenue Credits
Revenue Requirement
Total Load
Idaho Power estimates the increase in OATT rates and associated transmission revenues
would be approximately 29%higher. These revenues would serve as a revenue credit to retail
customer rates. However, as reflected in the proposal, Idaho Power's retail customers would not
receive these benefits until Idaho Power files its next general rate case.
Staff recommends that Idaho Power pass the reduction in revenue requirement as a result
of this asset transfer and the subsequent change in the OATT rates to the retail customers when it
occurs. Because of the change in the OATT rates, the Company would be able to calculate the
actual difference in the amount received by comparing the new OATT tariff revenues to a
calculation using the old OATT rates. Staff proposes that this amount be flowed through the
PCA mechanism, beginning when the OATT rates change until the effective date when it is
reflected in base rates. In the alternative, Staff recommends that these revenue amounts be
deferred in a regulatory account and flow back to customers in the next general rate case.
d. Financial Benefits to PacifiCorp and its Retail Customers
The benefits to PacifiCorp are largely related to the operation of PacifiCorp's
transmission system. As with Idaho Power, the financial benefit to retail customers stems not as
much from the transfer of assets, but from the replacement of the various legacy agreements with
the Legacy Replacement. According to PacifiCorp witness Vail, as shown in Exhibit 8,
PacifiCorp's revenue requirement would be reduced by approximately $1.6 million over a ten-
year period, on a present value basis. This savings is derived primarily from the impact the
transaction would have on PacifiCorp's wheeling and use-of-facilities costs. Without the asset
transfer, PacifiCorp's wheeling and use-of-facilities costs across the ldaho Power transmission
system are projected to be $20.8 million in2016, escalating each year thereafter. After the
11STAFF COMMENTS APRIL 22,2015
transfer, these costs would start at an initial $ 17.1 million per year and there would be no use-of-
facilities costs.
PacifiCorp's retail customers would not receive these benefits until PacifiCorp files its
next general rate case as currently reflected in the proposal. Staff recommends that the financial
benefits from the change in the wheeling and use-of-facilities costs be passed onto customers
when it occurs. Absent arate case, Staff recommends these benefits flow through the ECAM
mechanism until the effective date when the changes are reflected in base rates. In the
alternative, Staff recommends that these revenue amounts be deferred in a regulatory account,
and be flowed back to customers in the next general rate case.
e. Other Financial Benefits
With this asset transfer, there would be additional indirect financial benefits to both
Parties' customers from increased transparency, and administrative flexibility. As detailed in
Idaho Power's and PacifiCorp's response to Staff Production Request No. 5, the current daily
administration of the Legacy Agreements is not only time consuming, but has required
significant legal expense over the years related to the interpretation of the Legacy Agreements.
The elimination of the Legacy Agreements and the accompanying activities associated with them
would result in avoided administrative costs, although the specific amount of the costs avoided
has not been estimated by the Parties.
f. Transmission Losses
Currently, the RTSA outlines how losses are repaid for the services provided under the
contract, and defines loss repayment for transmission and generator main step-up transformer
losses. Idaho Power and PacifiCorp are currently reviewing options for the loss calculations and
repayment options but have not yet determined a common methodology. See Response to Staff
First Production Request No. 10 at 12. Staff acknowledges that the Parties are developing a
revised method to allocate losses for the use of the transmission system within the other Party's
Balancing Authority Area. See Application, DI Grow at 13,lines 8-12. However, Staff
recommends the Parties submit the proposed common methodology when it is completed.
STAFF COMMENTS t2 APRIL 22,2015
7. REPORTING
Staff recommends that the Company file with the Commission all final documents
pertaining to the asset transfer. This includes the documents relating to the true-up at closing, the
final journal entries, as well as the updated list of the Parties' common equipment. Staff further
recommends that the Parties submit the proposed common transmission line loss methodology
when it is completed for Commission review.
In addition to the documents relating to the asset transfer, Staff requests a yearly filing
detailing the revenue benefits from the asset transfer. Specifically, Staff requests a yearly filing
from Idaho Power Company reporting the change in transmission revenue as a result of the
change in its OATT tariff and rates, whether filed in conjunction with the PCA, or as a report on
the deferral in the regulatory account.
Staff requests a yearly filing from PacifiCorp, reporting the change in wheeling expenses
as a result of the asset transfer and the change in Idaho Power's OATT tariff and rates, whether
filed in conjunction with the ECAM or as a report on the deferral in the regulatory account.
STAFF RECOMMENDATION
Based on its review of the Application and associated issues, Staff submits the following
recommendations:
l. That the Commission accept the Parties' proposal to exchange certain transmission
assets and find (1) that the transfer of assets is consistent with the public interest; (2)
that the costs and rates of existing electric service in the State of Idaho will not be
increased by reason of such transaction; and (3) that the Parties have a bona fide
intent and financial ability to operate and maintain the transferred assets in the public
service. Application at ll-12.
2. That the financial benefits to the retail customers of Idaho Power and PacifiCorp be
flowed back to customers via the PCA or ECAM once the transfer has been approved.
In the alternative Staff recommends a regulatory account be set up to capture the
financial benefits for retail customers for disposition in the next general rate case.
3. That the Parties submit the proposed common transmission line loss methodology
when it is completed.
l3STAFF COMMENTS APRIL 22,2015
4. That the Parties submit the final reporting and accounting documents as described in
the body of this document.
Respecttully submitted this ?1:A day of April20l5.
Technical Staff: Johanna Bell
Kathy Stockton
i:umisc/comments/ipcel4.4l_pacel4. I ldjhjbkls oomments
STAFF COMMENTS t4 APRIL 22,2015
Legacy Agreements Proposed to Terminate (See Application, JPSA, Exhibit E)
Antelope Substation Capacity Entitlement, Operation and Maintenance Agreement (Oct. 17, 1989,as
amended Feb. 8, 1990);
Draft Transmission Services Agreement (May 5, 1995);
Populus Project Construction Agreement (Mar. 2,20091;
Second Restated and Amended Transmission Facilities Agreement (Feb. 8, 20701;
First Revised Agreement for lnterconnection and Transmission Services (May 24,2OtO);
Hemingway Joint Ownership and Operating Agreement (May 3, 20L0);
Populus Joint Ownership and Operating Agreement (May 3, 2010);
Borah Series Capacitor Operation and Maintenance Agreement (Nov. 15, 2010);
Threemile Knoll Series Capacitor Operation and Maintenance Agreement (Apr. 4,2OlLl;
Restated Transmission Services Agreement (Apr. 29, 20111;
Letter Agreement regarding Bridger Switchyard 345 kV Breaker Replacements (Dec. 6, !9911;
Letter Agreement regarding Bridger-Goshen-Kinport Relay Replacement (Dec. 13, 1991);
Letter Agreement regarding Additional Capacitors at the Jim Bridger Project and Kinport Substation
(Aug. 6, 79921;
Letter Agreement regarding the Loan of a Jim Bridger 345 kV Replacement Breakers for Temporary
lnstallation at the Kinport Substation as part of the Shunt Capacitor Project for ldaho Power Company
(Oct. 19, 1992)
Jim Bridger Ownership Agreement, dated as of September 22, !969, between ldaho Power Company
and Pacific Power & Light Company
Jim Bridger Operation Agreement, dated as of September 22,1969, between ldaho Power Company
and Pacific Power & Light Company
Attachment A
Case No. IPC-E-14-41/
PAC-E-14-11
Staff Comments
04/22ns
ATTACHME,NT B
IS CONFIDENTIAL
AND PROTECTED
UNDERTHE
PROTECTIVE
AGREE,MENT
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF APzuL 2015,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NOS. IPC-E-I4-4I /PAC-E.I4.l1, BY MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
JULIA A HILTON
IDAHO POWER CO
PO BOX 70
BOISE ID 83707
E-MAIL: [e-mail]
(Confi dential Attachment)
INDUSTRIAL CUSTOMERS OF IDAHO
POWER
C/O PETER J. RICHARDSON
RICHARDSON ADAMS PLLC
515 N. 27TH ST
BOISE, IDAHO 83702
E-MAIL: oeter@.richardsonadams.com
(Confidential Attachment)
DANIEL SOLANDER
TED WESTON
ROCKY MOUNTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 8411I
E-MAIL: [e-mail]
ted.weston@nacihcorp. com
(Confi dential Attachment)
DR. DON READING
6070 HILL ROAD
BOISE,IDAHO 83703
E-MAIL: [e-mail]
(Confi dential Auachment)
CERTIFICATE OF SERVICE