20251019Comment_1.pdf

From: Shauna Robinson <[e-mail]>
Sent: Sunday, October 19, 2025 7:36 PM
To: secretary<[e-mail]>
Subject: Letter RE: IPC-E-25-08
Dear Secretary Barrios-Sanchez:
Please find attached my opposition letter regarding"Idaho Power's Application for
Certificate of Public Convenience and Necessity for an ownership interest in the SWIP-N
transmission line and approval of the Utilization of the Capacity of the Line in IPC-E-25-
08:'
Thankyou.
Sincerely,
Shauna Robinson
19 October 2025
Monica Barrios-Sanchez
Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
Sent electronicallyto: [e-mail]
Dear Secretary Barios-Sanchez:
"Comments opposing Idaho Power's Application for Certificate of Public Convenience and
Necessity for an ownership interest in the SWIP-N transmission line and approval of the
Utilization of the Capacity of the Line in IPC-E-25-08"
As a resident of southern Idaho, I have serious concerns about Idaho Power applying for
IPC-E-25-08. I became familiar with the planned SWIP-N transmission line project over the
Last few years while serving on committees dealing with the Lava Ridge Wind Energy
proposal, which included the Twin Falls County Historic Preservation Commission, the
BLM RAC's Subcommittee on Lava Ridge, and the Stop Lava Ridge opposition group. The
planned 500kV transmission line from the Idaho-Nevada line, north to the Snake River
Canyon and on to the Midpoint Substation eight miles south of Shoshone, raises numerous
questions and concerns about power rates for Idaho consumers, the impacts to cultural
resources on both private and public lands along its 67-mile path, and the need of the
north-south line.
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Originally, SWIP-N was presented as aline necessary for the transfer of power from
southern Idaho's wind energy projects, i.e., Lava Ridge,Taurus, and Salmon Falls. Lava
Ridge in particular faced strong opposition because of the planned transfer of power to
California at the expense of Idaho's cultural and natural resources that are unique to our
public lands. But now that the Trump Administration has canceled the wind projects, there
is no local wind energy to send to California. Nonetheless, LS Power affiliate, Great Basin
Transmission has proposed "the purchase and sale of surplus energy into and from the
broader Mountain West and Pacific Northwest for Idaho consumers,"with Idaho Power
possibly becoming a partial owner of SWIP—N, pending approval by the Idaho Public
Utilities Commission. Approval of the project would send wind power from Idaho to
California that would help the California Public Utility Commission reach its energy goal of
acquiring 1.1 GW of wind energy from Idaho. If the large wind projects on public lands have
been canceled, what is the source of wind energy? Also, putting Idaho into the California
energy market through the power lines of SWIP-N may not be well-received either for
several reasons-1) Ida) Usingayers could be at risk for potential financial obligations of
such a partnership; 2) Such financial obligations might come on top of a possible 13% rate
increase that Idaho Power has recently requested; and 3) Using private and public lands
for the utility line's corridor in areas that already have transmission lines is unpopular. This
adds to my questioning of Idaho Power becoming a participant in the SWIP-N transmission
Line. Can it be a trusted arrangement or will it end up putting Idaho consumers at risk for
unwanted energy costs to satisfy the demands of the California market?
What is certain is that the public has not had many opportunities to learn about the SWIP-N
corridor since the initial public meetings in the 1990s when the BLM granted the Right of
Way(ROW)to Idaho Power, followed by the acquisition of the ROW in 2010 by LS Power
Development, LLC. Much has changed since 2010 in terms of population growth,
modifications in land use, and changes in property ownership. Yet, requests from
concerned citizens to local and federal officials for renewed public meetings have not been
realized. Public hearings for the effected counties are warranted, especially since there will
be many impacts on public and private lands with the construction of such a large 500kV
transmission line and demands that the company show a true need for the project. The
need for the line was even question by the Federal Energy Regulatory Commission (FERC)
on February 20, 2025, when they denied LS Power requests for cost recovery in the event
the transmission line was abandoned; FERC determined that LS Power did not adequately
address the benefits of the transmission line's construction. So why should Idaho Power
be allowed to be part of a project that creates questions about its benefits?
Of special concern to many are the additional physical and visual impacts to the cultural
resources along the SWIP-N transmission line corridor through Jerome and Twin Falls
Counties. In addressing the potential impacts on historical resources and properties, the
Elko and Twin Falls District Offices of the BLM, and LS Power have been coordinating
efforts since 2020 to meet the federal standards of Section 106 regarding effects on
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historic properties. Once completed, a Memorandum of Understanding will be finalized, a
process also involving the State Historic Preservation Offices (SHPO) in Idaho and Nevada.
This arrangement follows a ten-year period (2010-2020) after LS Power originally acquired
the ROW in which LS Power was to complete requirements for a Programmatic Agreement
(PA). They failed to meet those requirements which led to the BLM taking over the Section
106 process in 2020 that continues today. It amazes me that LS Power did not take the
obligations of their ROW acquisition more seriously, in not completing their PA
responsibilities.
Still another example of unfulfilled requirements was Great Basin Transmission's
application to Jerome County for a special-use permit to place the transmission towers for
SWIP-N across a 24-mile stretch of Jerome County. In a special appeals hearing on
October 7, 2025, the Jerome County Commissioners voted 2-1 to not grant the permit to
Great Basin Transmission because not all the conditions for the special use permit had
been met.
As a member of the Twin Falls County Historic Preservation Commission for over twenty
years, potential impacts on cultural resources with SWIP-N's construction is of major
concern. I understand that the BLM is surveying the historic/cultural resources within a
defined, ten-mile-wide corridor in which the transmission towers/line will occupy the
center; the center path will measure 200 feet wide. For five miles on either side of the
center is the Area of Projected Effects (APE)that serves as the critical area for potential
impacts physically and visuallyto historic and archaeological sites. Many significant
National Register and eligible sites are within the APE in both Jerome and Twin Falls
Counties. For instance, the Minidoka National Historic Site, segments of the Northside
Alternate of the Oregon Trail, the Dimond Family Barn (Tom Barnes Barn 1930), Sugarloaf
School (1924), lava rock farm buildings from turn of the century, 191" century placer mining
and Depression-era placer mining sites in Snake River Canyon near the Hansen Bridge, the
Rock Creek Store and Stricker Ranch, the Brose House, the 1896 site of the sheepherders
murder in the Diamondfield Jack case on Deep Creek(, the 191" century Toano Freight
Road, and many Native American sites as documented by the BLM. Individuals and groups
Like the Twin Falls County Historic Preservation Commission have spent thousands of
dollars in grant money to preserve unique and special sites in our county for the public to
enjoy and learn from, now and in the future. The presence of the SWIP-N line would only
diminish the historic integrity and character of these sites.
One of the most important historic sites in Jerome County is the Minidoka National Historic
Site, the Hunt Camp, that unjustly imprisoned 13,000 Japanese Americans after the Pearl
Harbor attack. The meaningful views offered by the open and isolated landscape of the
Minidoka National Historic Site are sacred to the descendants and survivors of the WWII
incarceration camp, who honor their family members by participating in annual
pilgrimages. The viewshed and that of other heritage properties should not be interrupted
with a transmission line, and protection of the site should be expanded.
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The planned construction of a 500kV line through Jerome and Twin Falls Counties presents
many challenges about impacts on private and public lands and the cultural resources
found within them. It also poses questions about the feasibility of building a transmission
Line to primarily serve the interests and energy goals of California through an Idaho
company(Idaho Power), especially when that line could potentially invite higher energy
costs and future wind farm construction across southern Idaho, something Idahoans have
shown they are adamantly against. With more public involvement, perhaps better answers
can be found for balancing our energy needs, without compromising our property rights,
heritage, and pocketbooks.
Thank you for your consideration.
Respectfully,
Shauna Robinson
shaunarobinson630(«)gmail.com
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