20191016Idaho Power Comments.pdf

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JULIA A. HILTON
Deputy General Counsel
and Director of Legal
ihi [e-mail]
October 16,2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re Case No. PAC-E-19-11
Application for Approval of the Asset Sale Between Rocky Mountain
Power and ldaho Power - ldaho Power Company's Comments in Support
of Application
Dear Ms. Hanian
Enclosed for filing in the above matter are an original and seven (7) copies of
ldaho Power Company's Comments in Support of Application.
Very truly yours,
r
Ju ia A. Hi
JAH:kkt
Enclosures
JULIA A. HILTON (lSB No. 7740)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
i h ilton@ idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
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IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF THE ASSET SALE
BETWEEN ROCKY MOUNTAIN POWER
AND IDAHO POWER
CASE NO. PAC-E-19-11
IDAHO POWER COMPANY'S
COMMENTS IN SUPPORT OF
APPLICATION
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ldaho Power Company ("ldaho Power" or "Company"), by and through its
undersigned attorney, hereby submits to the ldaho Public Utilities Commission
("Commission") these Comments supporting the Application in the above-captioned
proceeding.
I. BACKGROUND
ldaho Power is a public utility in ldaho pursuant to ldaho Code S 61-129 and is a
transmission provider which owns and operates facilities for the transmission of electricity
in ldaho and Oregon. As stated in the Application, ldaho Power currently owns a 3.6
percent undivided ownership interest in 29 contiguous miles of the American Falls to
Wheelon 138 kilovolt ("kV") line ("the Line"), beginning from the American Falls substation
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF APPLICATION - 1
and extending southeast into the Arbon Valley, pursuant to a Commission-approved Joint
Purchase and Sale Agreement.l ldaho Power and PacifiCorp jointly own the line as
tenants in common, subject to the terms and conditions of a Joint Ownership and
Operation Agreement ('JOOA').
II. COMMENTS
As the Application describes, ldaho Power plans to construct a 138-kV substation
in the Arbon Valley area, approximately one mile beyond the point of ldaho Power's
current ownership interest in the Line. As a result, ldaho Power desires to acquire a 3.6
percent undivided interest in one additional mile of the Line. PacifiCorp agreed to sell
such interest to ldaho Power. The parties entered into a bill of sale, which is subject to
the receipt of required authorization from this Commission, and which was included with
the Application. The bill of sale reflects the sale of an additional one-mile, 3.6 undivided
interest in the Line in exchange for a payment by ldaho Power to PacifiCorp.
The Application is subject to and meets the requirements of ldaho Code S 61-328,
which requires Commission approval for the sale of utility property, or an interest therein,
located in ldaho which is used in the generation, transmission, distribution, or supply of
electric power and energy to the public. ln order to authorize such a transaction, the
Commission evaluates:
(a) That the transaction is consistent with the public interest;(b) That the 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 bona fide
intent and financial ability to operate and maintain such property in the
public service.
ldaho Code S 61-328
I Case No. IPC-E-14-41, Order No. 33313
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF APPLICATION - 2
While ldaho Power recognizes that the transferor of property must meet these
requirements, the Company believes that the requirements in this case are also met when
evaluated from the perspective of the receiver of property. The transaction is in the public
interest because it will allow ldaho Power to appropriately plan for and serve its customers
in the Arbon Valley. The additional one mile will facilitate efficient and cost-effective
planning and construction of new facilities (the 138-kV substation) to serve load. ln
addition, the cost of and rates for supplying service will not be increased by this
transaction. ldaho Power's payment for the property is minimal and ldaho Power is not
seeking to change its rates as a result of this transaction. Finally, ldaho Power is a public
utility in ldaho that owns and operates a substantial amount of similar facilities for the
transmission of electricity in ldaho, and thus has the bona fide intent and financial ability
to operate and maintain such property in the public service.
ln conclusion, ldaho Power fully supports the Application. The transaction satisfies
the criteria in ldaho Code S 61-328, and ldaho Power respectfully urges the Commission
to authorize the transfer of property.
DATED at Boise, ldaho, this 16th day of October 2019.
IAA
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF APPLICATION - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16th day of October 2019 I served a true and
correct copy of IDAHO POWER COMPANY'S COMMENTS lN SUPPORT OF
APPLICATION upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Matt Hunter
Deputy Attorney General
ldaho Public Utilities Commission
1 1331 W. Chinden Boulevard
Building 8, Suite 201-A (83714)
P.O. Box 83720
Boise, ldaho 83720-007 4
Hand Delivered
_U.S. Mail
_Overnight Mail_FAXX Email matt [e-mail]
Rocky Mountain Power
Daniel E. Solander
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
Hand Delivered_U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
Ki T Assistant
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF APPLICATION - 4