20240805Comment_1.pdf

From: [e-mail]<[e-mail]>
Sent: Saturday, August 3, 2024 5:16 AM
To: Davenport, Christy; Monica Barrios-Sanchez; secretary
Cc: 'Walker, Donovan'; Dayn Hardie; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail]; Tom
Arkoosh; Erin Cecil; [e-mail]; 'Fritz Haemmerle'
Subject: RE: IPC-E-24-22 - Wood River Valley Surcharge Compliance Filing - Idaho Power
Company's Response to the First Production Request of the Commission Staff
Idaho PUC,
I would like my previous case comments, attached, submitted to this current case IPC-E-24-22 as
well; the issues are still the same.
Kiki Leslie A. Tidwell
Kiki Tidwell
433 US Rte 1 #213
York, ME 03909
650-388-2108
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COMMENTS ON CASE IPC-E-21-25- I

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER Case No. IPC-E-21-25
COMPANY'S PETITION FOR APPROVAL
OF A CUSTOMER SURCHARGE AND
MODIFIED LINE ROUTE COMMENTS ON CASE
CONFIGURATION FOR CONSTRUCTION
OF A NEW 138 kV TRANSMISSION LINE
IN THE WOOD RIVER VALLEY
Kiki Leslie A. Tidwell, Intervenor, hereby files comments on Case IPC-E-21-25 pursuant
to Rules of Procedure 71 through 75 of the Idaho Public Utilities Commission, ID APA
31.01.01.071-.075 as follows:
1. The name and address of this Intervenor is:
Kiki Leslie A. Tidwell
704 N. River St. #1
Hailey, ID 83333
[phone]
[e-mail]
2. While Idaho Power ignores that there is an appeal ongoing at the Idaho Supreme
Court on the legality of the Blaine County Commissioners' actions on this transmission line, the
company is requesting that all Idahoans pay for undergrounding transmission lines in the city of
Ketchum for approximately $14 million, as well as undergrounding from the County hospital
area to Ketchum for another couple $ million. Yet in the same case it contends that only Blaine
County residents must pay for undergrounding distribution lines between Hailey and the
hospital. How can Idaho Power possibly make the two arguments in the same case? The Idaho
PUC's staff Michael Morrison, in his May 5 2017 testimony, wrote that the undergrounding in
Ketchum is primarily for aesthetic reasons. A strong case has not been made that all Idahoans
should pay for this non-essential undergrounding of transmission lines in the City of Ketchum.
COMMENTS ON CASE IPC-E-21-25-2

Idaho Power has vaguely referred to power poles in Ketchum creating traffic hazards or the cost
of securing new easements. However,just as between Hailey and Ketchum, Idaho Power
already has distribution lines in Ketchum on which it could mount transmission lines through
existing easements on stacked configurations like it designed between Hailey and the hospital.
3. In contrast, Idaho Power has clearly taken the stance that the tariff to Blaine County
residents to underground distribution lines between Hailey and the hospital is non-essential to
electrical service through their attorney Donovan Walker's letter to Blaine County, "This 3
percent threshold is consistent with the current 3 percent cap on franchise fee collection by city.
If implemented, many city residents within Blaine County (Bellevue, Hailey, Ketchum, and Sun
Valley)would pay a total of 6 percent of their Idaho Power bills toward costs not required for the
provision of safe, reliable electric service."
4. All Idaho ratepayers are being asked not only to pay for approximately $17 million of
undergrounding costs, but an additional $13-$20 million for a second transmission line between
Hailey and Ketchum. This project was started initially approximately 15 years ago to repair the
existing transmission line. Now the project does not even contain the costs of repairing the
initial line. A lot of testimony by Idaho Power has been on the need to create redundancy, but if
the first line is still in such dire danger of failure, how has true redundancy been achieved?
Michael Morrison, in his May 5 2017 direct testimony in case IPC-E-16-28, stated that"Full
redundancy comes at a high cost because it requires the Company to fully duplicate the existing
transmission line... it would only have provided a very small benefit for its $30 million cost."
Idaho Power has not made the financial case that all Idaho ratepayers should pay for a second
transmission line to Ketchum; it would be much less expensive to run a temporary line and repair
the first one.
COMMENTS ON CASE IPC-E-21-25-3

5. Meanwhile over the last 15 years, energy storage costs have come down
exponentially and many, many communities in other states are finding that it is cheaper to install
"non-wires" solutions of backup generators and batteries at all substations close to loads than to
install transmission lines. In the largest power outage of Blaine County Christmas eve 2009, no
power reached the Hailey Wood River substation, so no power could be transmitted north, no
matter how many transmission lines there are. Idaho Power is incorrect in stating that a
transmission line is a source of power; it is only conduit for power transmission and does not
produce power in and of itself. In fact, and although it is late to the table, Idaho Power now has a
plan to install megawatts of battery installations at sub-stations in Idaho in its latest IRP
preferred plan. If there is such a dire situation that the original transmission line is in danger of
failure, Idaho Power should begin to immediately install some of these MWs of batteries in all
the substations north of the hospital.
6. Idaho Power's IPC-E-21-25 request is a regressive tariff request; the smallest
ratepayers in the most modest of homes in Blaine County will be paying proportionally more of
their income towards this tariff for the next 20 years. What will a homeowner in Carey, Idaho
get for this undergrounding of distribution lines between Hailey and Ketchum and the
undergrounding of transmission lines in Ketchum? Certainly not improved electrical security for
themselves.
7. Maybe it is difficult for Idaho Power to relate to homeowners who struggle with
financial insecurity as they seem to compensate themselves well. IdaCorp's chairman Richard J.
Dahl resides in Hawaii and received$308,976 in board director compensation in 2020. The nine
directors of IdaCorp, Inc. each earned from $183,655 to $269,363 total compensation in 2019.
Darrel Anderson received significant compensation for many years as CEO, up to $8,271,701
COMMENTS ON CASE IPC-E-21-25-4

million in total compensation as CEO in 2019. Anderson did well for himself over the years,
increasing his salary to these astronomical heights. Darrel Anderson's total annual compensation
without change in Pension Value doubled in the 6 years from 2014 to 2020. His total annual
compensation with Pension Value was noted in the 2012 proxy as $1,836,644 and in 2019 had
grown to $8,271,701. In contrast, CEO LaMont Keen's 2011 base salary was $634,423 and
"Mr. Anderson's November 2011 promotion.......resulting in a significant increase in the market
median base salary from $383,000 in 2011 (for his prior position)to $505,000 in 2012." The
amount paid to CEO Darrel Anderson from 2014 through 2020 was $33,600,330. According to
IdaCorp. Inc's Proxy Statements 2011-2020, Darrel Anderson earned the following amounts of
total compensation once he became CEO in 2014 through in June 2020, when he stepped down
from the CEO position,but remained on the Board of Directors:
Without chanfze in Pension Value Total
2020, half year $3,704,448 $6,318,342
2019, $4,733,097 $8,271,701
2018, $4,474,464 $5,376,529
2017, $3,933,876 $6,695,596
2016, $3,548,020 $5,594,126
2015, $2,476,533 $3,617,649
2014, $2,115,872 $4,044,729
8. In IdaCorp., Inc.'s 2021 Proxy Statement', the Company noted that the Quarterly
Dividend has increased 137% since 2011. It seems that the Idaho PUC's Stipulation No. 30978
and rate case settlement of 2011 have enriched Idaho Power and IdaCorp., Inc. coffers, and in
1 https:Hs26.g4cdn.com/720254477/files/doc_financials/annual/2020/prxy2O2l.pdf
COMMENTS ON CASE IPC-E-21-25-5

particular, the compensation of senior management,board directors, and most egregiously,
Darrel Anderson, in the years since.
9. Due to the federal Covid economic relief legislation, federal funds have been
distributed to the states, and Idaho's Governor has since provided tax relief to many Idaho
ratepayers. Is this a windfall to Idaho Power? Anderson's 2011 testimony discussed a prior
repairs allowance tax benefit which occurred in 2010 and its positive effect on their ROE. Could
not a similar situation be ongoing now with tax relief in the state of Idaho? The Company should
disclose how such beneficial tax relief may be increasing their ROE higher than the authorized
ROE of 10.5%.
10. A federal infrastructure bill has been passed with federal funds for transmission and
other infrastructure projects. Why should the most financially struggling ratepayer in Idaho pay
for a gold-plated transmission line project in Blaine County just so that Idaho Power can earn an
increased ROE of 10.5% on this project cost?Why should the most financially struggling
Bellevue ratepayer also pay the extra egregious —10% interest rate charged by Idaho Power to
Blaine County residents for undergrounding distribution lines between Hailey and the hospital?
11.There are numerous studies on the benefits to the grid and to all ratepayers when on-
site generation and micro-grids can reduce load at peak power demands. As Idaho Power
conducts its 2021 Integrated Resource Planning process, additional generation resources are
being explored to be built to cover increased peak loads. 900 MWs of generation has been
identified to be built. All Idaho ratepayers benefit when Idaho Power is knowledgeable up to
2021 levels of information about the benefits of microgrids and battery storage which reduce the
need to build additional peaker plants. The company should be required to research and provide
such studies.
COMMENTS ON CASE IPC-E-21-25-6

12. Idaho Power did not do an adequate exploration of non-wires alternatives, the price
of which has declined exponentially in the last ten years, and which are being installed in lieu of
transmission in many states and countries today. Microgrids, batteries, backup diesel generators,
and other distributed generation close to loads provide larger resilience to communities than
overhead wires vulnerable to fire or ice storms. IPCo's plan has the second proposed
transmission line located within yards of the first on Buttercup Road; if a fire or ice storm
impacts the original line, there is the strong probability that it will impact the second line as well.
13. I was an Intervenor in IPC-E-16-28. In documents provided to me as an Intervenor,
Idaho Power provided internal meeting minutes which detailed how IPCo carefully selected
CAC members to ensure "the committee's support of our desired outcomes."As well Idaho
Power gave the CAC only selected materials and guided the CAC to only proposals that were in
boundaries that IPCo had determined, "the committee will know right off the bat if we weren't
willing to accept their proposals." Idaho Power stacked the deck of their hand-selected Citizens
Advisory Committee in order to achieve a financial outcome for themselves, a 10.5%percent
return on project costs of$30-$35 million.
14. Idaho Power, as a for-profit corporation, benefits financially from this project at the
expense of Idaho ratepayers. Idaho ratepayers would be better served by a cost effective project
of distributed generation; batteries and generators at sub-stations which provide true resiliency
and more financial benefit to all Idaho ratepayers through microgrids which would alleviate the
need for expensive and under-utilized peaker plants. Idaho ratepayers would benefit greatly by
the Idaho PUC also undertaking a new base rate case in parallel at this time as it is long overdue
and small ratepayers are subsidizing outsized salaries and profits at Idaho Power and IdaCorp.,
Inc.
COMMENTS ON CASE IPC-E-21-25-7

15. The Idaho PUC may dimiss my pro-se comments as only annoying. Yet, I spoke up
in 2008 when Idaho Power wanted to build a coal-fired power plant in Idaho. Due to my
successful shareholder initiative alerting the company to the business risk of building this fossil-
fuel asset and requesting the company reduce carbon in its power production portfolio, the
company pivoted away from coal. As a result, the company and ratepayers were not stuck with
costs of stranded assets of coal plants in the new normal of climate change. Idaho Power has
been attached to this new $35 million transmission line, including—$17 million for
undergrounding north of the hospital, for at least the past ten years as it sees the financial benefit
to itself. However,the PUC may want truly represent the ratepayers of Idaho in denying this
request that ratepayers pay for this gold-plated windfall for Idaho Power.
DATED this 14th day of December, 2021.
Leslie A. Tidwell
Pro Se
COMMENTS ON CASE IPC-E-21-25-8

CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 14th of December 2021
I served a true and correct copy of IDAHO POWER COMPANY'S PETITION FOR
APPROVAL OF A CUSTOMER SURCHARGE AND MODIFIED LINE ROUTE
CONFIGURATION FOR CONSTRUCTION OF A NEW 138 kV TRANSMISSION LINE IN
THE WOOD RIVER VALLEY upon the following named parties by the method indicated
below, and addressed to the following:
Donovan E. Walker, Idaho Power Company
P.O. Box 70 Boise, Idaho 83707-0070
U.S. Mail
Overnight Mail
Hand Delivery
Fax
X Email dwalkergidahopower.com, [e-mail]
Timothy E. Tatum, Idaho Power Company
P.O. Box 70 Boise, Idaho 83701-0070
U.S. Mail
Overnight Mail
Hand Delivery
Fax
X_Email [e-mail]
John Hammond, Jr.
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8 Ste 201-A
Boise, ID 83720-0074
U.S. Mail
Overnight Mail
Hand Delivery
Fax
X_Email [e-mail]
Blaine County Board of Commissioners
COMMENTS ON CASE IPC-E-21-25-9

Ronald L. Williams, Williams Bradbury, P.C.
PO Box 388
Boise, ID 83701
Email: [e-mail]
U.S. Mail
Overnight Mail
Hand Delivery
Fax
X Email rongwilliamsbradbury.com
Prosecuting Attorney
219 First Ave. South Ste 201 Timothy Graves
Chief Deputy
Hailey, ID 83333
U.S. Mail
Overnight Mail
Hand Delivery
Fax
X Email [e-mail]
Bradley G. Mullins
MW Analytica, Energy &Utiltiies
U.S. Mail
Overnight Mail
Hand Delivery
Fax
X_Email [e-mail]
Cox Communications
C. Tom Arkoosh, Arkoosh Law Offices
PO Box 2900
Boise, ID 83701
U.S. Mail
Overnight Mail
Hand Delivery
Fax
X Email tom.arkoosh(d,arkoosh.com
Erin.cecilkarkoosh.com
Mark DiNunzio
COMMENTS ON CASE IPC-E-21-25- 10

U.S. Mail
Overnight Mail
Hand Delivery
Fax
X Email mark.DiNunzio(&cox.com
Kiki Leslie A. Tidwell
COMMENTS ON CASE IPC-E-21-25- 11