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HomeMy WebLinkAbout20260403Direct Vail.pdf RECEIVED APRIL 3, 2026 IDAHO PUBLIC UTILITIES COMMISSION BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY AND ) CASE NO. IPC-E-26-09 PACIFICORP D/B/A ROCKY MOUNTAIN ) POWER FOR CERTIFICATES OF PUBLIC ) CASE NO. PAC-E-26-06 CONVENIENCE AND NECESSITY FOR ) SEGMENT E-8 OF THE GATEWAY WEST ) 500-KV TRANSMISSION LINE . ) IDAHO POWER COMPANY DIRECT TESTIMONY OF RICK A. VAIL TABLE OF CONTENTS 1 I . INTRODUCTION AND QUALIFICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . 2 2 II . PURPOSE AND SUMMARY OF TESTIMONY. . . . . . . . . . . . . . . . . . . . . . . . 3 3 III . PACIFICORP' S TRANSMISSION SYSTEM AND GWWE-8 . . . . . . . . . . . . . 4 4 IV. PRE-CONSTRUCTION, DESIGN, AND PERMITTING ACTIVITIES . . . . . 8 5 V. CONCLUSION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 VAIL, DI - 1 Rocky Mountain Power 1 I . INTRODUCTION AND QUALIFICATIONS 2 Q. Please state your name, business address, and 3 present position with PacifiCorp. 4 A. My name is Rick A. Vail . My business address is 5 825 NE Multnomah Street, Suite 1600, Portland, Oregon 97232 . My 6 present position is Vice President of Transmission. I am 7 responsible for transmission system planning, customer generator 8 interconnection requests and transmission service requests, 9 regional transmission initiatives, asset management, capital 10 budgeting for transmission, and administration of the Company' s 11 Open Access Transmission Tariff ("OATT") . I am testifying on 12 behalf of PacifiCorp d/b/a Rocky Mountain Power (the "Company") . 13 Q. Please describe your education and professional 14 experience. 15 A. I have a Bachelor of Science Degree with Honors in 16 Electrical Engineering with a focus in electric power systems 17 from Portland State University. I have been employed at the 18 Company since 2001 and have had a range of management 19 responsibilities within the asset management group, including 20 capital planning, maintenance policy, maintenance planning, and 21 investment planning. I served as Director of Asset Management 22 from 2007 to 2012 . 1 became Vice President of Transmission in 23 December 2012 . 24 VAIL, DI - 2 Rocky Mountain Power 1 II . PURPOSE AND SUMMARY OF TESTIMONY 2 Q. What is the purpose of your testimony? 3 A. Idaho Power and PacifiCorp (together, the "Parties" 4 or "each Party") are requesting the Commission issue an order 5 granting each Party a Certificate of Public Convenience and 6 Necessity ("CPCN") for Segment E-8 of the Gateway West 500- 7 kilovolt ("kV") line ("Segment E-8" or GWWE-8") , the Midpoint to 8 Hemingway 500-kV transmission line (the "Project") . My testimony 9 supports the Company' s application for a CPCN for Segment E-8 . 10 The Project is a sub-segment of the Energy Gateway West Segment 11 E transmission line from Populus to Hemingway which consists of 12 two single-circuit 500-kV lines that run approximately 616 miles 13 between the Populus Substation in eastern Idaho, to the 14 Hemingway Substation in western Idaho. 15 My testimony and exhibit provide information required by 16 Idaho Public Utilities Commission ("Commission") Rules of 17 Procedure 52 and 112 and Idaho Code § 61-526, related to 18 applications for CPCNs, for GWWE-8 . 19 Q. Please summarize your testimony. 20 A. Segment E-8 is necessary for the Company to meet 21 its customers' short- and long-term energy demand, and will 22 strengthen the overall reliability of the existing transmission 23 system. Gateway West Segment E has long been recognized as an 24 integral component of the Company' s long-term transmission 25 planning. Current planning studies identify a need for the VAIL, DI - 3 Rocky Mountain Power I entire segment by 2036 . Due to the structure of the Amended and 2 Restated Gateway West Transmission Project Development Agreement 3 ("Project Development Agreement") between the Parties for Energy 4 Gateway West, PacifiCorp will maintain a one percent ownership 5 share of Segment E-8 . 6 III . PACIFICORP' S TRANSMISSION SYSTEM AND GWWE-8 7 Q. Please briefly describe PacifiCorp' s transmission 8 system. 9 A. PacifiCorp owns and operates approximately 17, 000 10 miles of transmission lines ranging from 46-kV to 500-kV across 11 multiple western states . PacifiCorp has over 2 million customers 12 with approximately 88, 000 customers located in Idaho. Idaho is 13 located (along with Wyoming and Utah) in PacifiCorp' s eastern 14 Balancing Authority Area ("BAA") , PACE, which has over 12, 640 15 circuit-miles of transmission lines and a record peak demand of 16 13, 195 megawatts ("MW") . 17 Q. Is PacifiCorp' s transmission system interconnected 18 with any third-party systems? 19 A. Yes . PACE alone is interconnected with 17 other 20 systems, including Arizona Public Service, Bonneville Power 21 Administration ("BPA") , NV Energy, Los Angeles Department of 22 Water & Power, NorthWestern Energy, Western Area Lower Colorado- 23 Phoenix, Idaho Power Company ("Idaho Power") , Western Area 24 Colorado Missouri-Loveland, Western Area Power Administration, 25 Black Hills Power, Utah Associated Municipal Power Systems, Utah VAIL, DI - 4 Rocky Mountain Power 1 Municipal Power Agency, Deseret Power Electric Cooperative, 2 Basin Electric Power Cooperative, Intermountain Power Agency, 3 Tri-State Generation & Transmission Association, and Public 4 Service Company of New Mexico. 5 Q. Please describe the Project, and Project route . 6 A. As depicted in Map 1, the Project includes building 7 a new 133-mile single-circuit 500 kV transmission line between 8 the Midpoint Substation in Jerome, Idaho, and the Hemingway 9 Substation in Melba, Idaho. 10 Map 1—Gateway West Segment E-8 Map GATEWAY WEST TRANSMISSION LINE PROJECT ORPGON - carv•� `�- r ... a Segment E-8 Base - Gateway West project AC�A BLMappr—d SubflaWn "' Vr „ " r.. - • (E-1 anawnl,rig.E.p J Hurn y 6DNVnr - _ �,___-� -SLMepp—ed SubetagonlNew) NBLMappmvad Seg—ril E-B ;. ,,, �/�Spmsnl ROW Anptrvad ID HO ROW 40".#BLM approved SegmenlE In* At CAV'Toanillinanew -••(,CUVNIY y rrI - - - =BLM FielBoundary •, I -1 ++'Y" _ ,,- �jGpunty County Boundary oundand ary Lad JlMfdi[*on Bureau of Land Alanagemenl Midpoint EureM semre Stale N r dt. QSrale Boundary N _ N Lapald(CQnLI land DeMgnatlon Area of Cnllcal En-onmental Mlles Concern InV•rarnle na d Roadlass A '�� �� g tg 81 L National Con—bon Area Nabwul Wnumenl Nabonal WIMIde Reluge Wild— Area • UTAH Wlldanese Study Area NEVADA .0 nnnel�ew N. PACIFICORP ru0_01Y-000Nn 11 12 After leaving Hemingway substation, the transmission line 13 extends south and east approximately six (6) miles through 14 Owyhee County. After crossing the Snake River, it continues east 15 approximately three (3) miles through Canyon County. It 16 continues east approximately 30-miles through Ada County, VAIL, DI - 5 Rocky Mountain Power I skirting the northern boundary of the Idaho National Guard' s 2 Orchard Combat Training Center. Upon entering Elmore County, the 3 transmission line crosses Interstate 84, then turns south and 4 east and continues approximately 56-miles through Elmore County. 5 The transmission line generally parallels the existing 6 Hemingway to Midpoint 500kV transmission line through Owyhee, 7 Canyon, Ada Counties, and the majority of Elmore County, and 8 also intersects with the Morley Nelson Snake River Birds of Prey 9 National Conservation Area (NCA) at multiple locations within 10 these same counties . 11 After exiting Elmore County, the transmission line 12 continues in an easterly direction approximately 29 miles 13 through Gooding County, continues two and half (2 . 5) miles 14 through the southwest corner of Lincoln County; and continues 15 six (6) miles finally terminating at Midpoint substation in 16 Jerome County. 17 Q. What infrastructure is required for the line? 18 A. The Project requires constructing 30 . 3 miles of 19 single-circuit 500-kV transmission line through Ada County, 3 . 3 20 miles in Canyon County, 55 . 7 miles through Elmore County, 28 . 8 21 miles through Gooding County; 6 . 0 miles through Jerome County, 22 2 . 5 miles through Lincoln County, and 5 . 9 miles in Owyhee 23 County. 24 Additionally, GWWE-8 will require construction of the 25 following ancillary facilities : a new communication station near VAIL, DI - 6 Rocky Mountain Power 1 King Hill in Elmore County; approximately 60 miles of new access 2 roads and 16 miles of temporary roads; modification of 3 approximately 404 miles of existing roads . 4 Q. What is the total cost estimate for the Company' s 5 share of the Project? 6 A. The Company estimates that its in-service cost of 7 the Project will be $9 . 10 million, including AFUDC. 8 Q. Has the Company put in place any cost controls for 9 the Project? 10 A. Yes . Operating under the existing Project 11 Development Agreement including the current preconstruction 12 phase, the Company utilizes best practice project controls 13 including monthly tracking of budgets, forecasts, and schedules . 14 Professional Services required to support permitting and 15 preconstruction activities were competitively bid. The project 16 budget adheres to all Company project controls and governance . 17 Q. When does the Company expect construction of the 18 Project to be complete? 19 A. As discussed in Idaho Power Witness Ms . Lindsay 20 Barretto' s Direct Testimony, Idaho Power will take over 21 management of the Project when construction activities begin and 22 has informed the Company that it expects to complete 23 construction of Phases I and II in late 2028 and Phase III in 24 summer 2030 . VAIL, DI - 7 Rocky Mountain Power 1 IV. PRE-CONSTRUCTION, DESIGN, AND PERMITTING ACTIVITIES 2 Q. What is PacifiCorp' s role in developing the 3 Project? 4 A. Under the initial Project Development Agreement 5 between Idaho Power and the Company (executed January 12, 2012, 6 and amended several times thereafter) , both Parties are required 7 to jointly support the regulatory processes associated with 8 obtaining necessary permits and other project development work. 9 When the Project is completed, Idaho Power and the 10 Company will jointly own, as tenants-in-common, the transmission 11 line and all associated facilities and equipment. ) Per the 12 Project Development Agreement, PAC is responsible for federal, 13 state, and local permitting efforts, engineering and design, and 14 pre-construction activities for the Project. 15 Q. Can you generally discuss PacifiCorp' s engineering 16 and design activities? 17 A. Segment E-8 will be constructed using approximately 18 540 structures utilizing self-supported single-circuit lattice . 19 Tangent lattice structures are designed to support the 20 conductors where the transmission line angle at the structure 21 location is typically 1° or less, meaning the transmission line 22 is essentially a straight line. Very similar structures by 23 appearance support the transmission line at a transmission line 24 angle (direction changes) up to about 220 . Dead end towers with 1 Id. at 26. VAIL, DI - 8 Rocky Mountain Power 1 more complex insulator assembles and heavier/stronger structures 2 will be used when transmission line angles are greater than 30° . 3 The self-supporting steel lattice structures will be 4 fabricated with galvanized steel members treated to produce a 5 dulled galvanized finish. The average distance between 500-kV 6 structures, or span, typically will range between 1, 200 to 1, 300 7 feet with occasional longer spans in challenging terrain. 8 Structure heights will vary depending on the terrain and the 9 requirement to maintain minimum conductor clearances from the 10 ground, but the 500-kV single-circuit structures will vary in 11 height from approximately 145 to 199 feet. Each transmission 12 line structure type is individually designed, depending on the 13 line angle and the underlying soil and rock conditions, to 14 withstand the pull of the wires in different directions . Each 15 transmission line structure will be set on self-supporting cast- 16 in-place concrete drilled piers . 17 The 500-kV single-circuit self-supporting steel lattice 18 structures each require four foundations, one at each of the 19 corners of the lattice structures . Typically, the foundations 20 for the self- supporting single-circuit tangent lattice 21 structures will be composed of steel-reinforced, drilled 22 concrete piers . Alternative foundation types may be used to 23 include grillage, precast pad and pedestal, screw piles, and 24 micropiles . Geologic or loading conditions as well as 25 environmental disturbance constraints, among other concerns, may VAIL, DI - 9 Rocky Mountain Power 1 necessitate the use of one or more of these alternatives and 2 impact the foundation diameter and/or depth. 3 Q. Can you please elaborate further on the conductor 4 used for GWWE-8? 5 A. The conductor for the lines is 1, 272 thousand 6 circular mil (kcmil) aluminum-conductor steel-reinforced (ACSR) 7 triple-bundled Bittern. For all 500-kV lines, each phase of the 8 three-phase circuit will be composed of three subconductors in a 9 triple-bundle configuration. The triple-bundle configuration 10 provides adequate current carrying capacity and provides for a 11 reduction in audible noise and radio interference as compared to 12 a single large-diameter conductor. Each 500-kV subconductor will 13 have a 45/7 aluminum/steel stranding, with an overall conductor 14 diameter of 1 . 345 inches, a weight of 1 . 432 pounds per foot, and 15 a non-specular finish. 16 Q. What additional capabilities will the line have? 17 A. Each structure will have two lightning-protection 18 shield wires installed on the peaks of each of the 500- kV 19 single-circuit steel lattice structures . One of the shield wires 20 will be composed of extra-high-strength steel wire with a 21 diameter of approximately 0 . 5 inch and a weight of 0 . 517 pound 22 per foot. The second shield wire will be an optical ground wire 23 (OPGW) constructed of aluminum and steel, which carries 48 - 96 24 glass fibers in its core. The OPGW will have a diameter of 25 approximately 0 . 64 inch and a weight of approximately 0 . 375 VAIL, DI - 10 Rocky Mountain Power 1 pound per foot. The glass fibers inside the OPGW shield wire 2 will provide optical data transfer capability among the Parties' 3 facilities along the fiber path for the Parties' operation of 4 the Project. The data transferred are required for system 5 control and monitoring. All 500-kV line elements of the Project 6 will be designed to carry an OPGW. 7 Q. Are any substation improvements required for the 8 Project? 9 A. Segment E-8 requires expansion of both the Midpoint 10 substation, located near Jerome, Idaho, and the Hemingway 11 substation, located near Walters Ferry, Idaho. Both the Midpoint 12 and Hemingway substations are existing substations . 13 Q. What improvements are needed for the Midpoint 14 Substation? 15 A. The Midpoint Substation is an existing substation 16 located on Idaho Power fee-owned property. The existing Midpoint 17 substation will be expanded by approximately 40 acres to 18 accommodate the Project. Expansion of the Midpoint substation 19 will include installation of a new 500-kV bay using conventional 20 air-insulated bus and equipment. Major facility/equipment 21 additions to be installed at Midpoint substation also includes 22 substation steel dead-end structures, circuit breakers and 23 related switching equipment, and bus work. All disturbance 24 necessary to support the expansion of the Midpoint Substation VAIL, DI - 11 Rocky Mountain Power 1 will occur within the approximately 40-acre permanent 2 disturbance expansion area. 3 Q. What improvements are needed for the Hemingway 4 Substation? 5 A. The Hemingway Substation is an existing substation 6 located on Idaho Power fee-owned property that will be modified 7 to add an additional bay using conventional air-insulated bus 8 and equipment, inside the current Hemingway Substation fence 9 line . All disturbance necessary to support the modification of 10 the Hemingway Substation will occur within the existing fence 11 line and an existing access road will be used to support 12 construction. 13 Major facility/equipment additions to be installed at Hemingway 14 Substation will also include substation steel dead-end 15 structures, circuit breakers and related switching equipment, 16 and bus work. 17 Q. Can you generally discuss PacifiCorp' s pre- 18 construction activities? 19 A. Permitting and pre-construction activities have 20 occurred to support the Segment E-8 since 2018 when the right- 21 of-way was granted by the Bureau of Land Management ("BLM") . 22 Following the initial introduction to federal and state 23 agencies, in 2023 the project was introduced to local agencies, 24 and the bulk of pre-construction activities began to move 25 forward. Pre-construction activities include environmental, VAIL, DI - 12 Rocky Mountain Power 1 cultural and paleontological surveys, obtaining the necessary 2 easements, and engineering design. 3 Q. What environmental, cultural and paleontological 4 surveys have been conducted? 5 A. In response to requirements set forth in Section 7 6 of the Endangered Species Act (ESA) , Section 106 of the National 7 Historic Preservation Act (NHPA) , the Paleontological Resources 8 Preservation Act, and Section 404 of the Clean Water Act (CWA) , 9 pedestrian field surveys have been conducted for the following: 10 • Special-status species of plants and wildlife . 11 • Cultural resources (a 100% Class III survey of the 12 area of potential effects) . 13 • Paleontological resources in geological units and/or 14 Potential Fossil Yield Classification 3, 4, and 5 as 15 identified by BLM paleontologists . 16 • Areas that were identified by National Wetland 17 Inventory data or aerial photo interpretation as 18 having large wetlands or wetland complexes and most 19 stream/wash crossings . 20 Q. What concerns do the surveys address? 21 A. The environmental field surveys are being conducted 22 in accordance with agency-approved survey protocols . Based on 23 the data resulting from the surveys, the agencies and the VAIL, DI - 13 Rocky Mountain Power 1 Companies coordinated to derive the following detailed 2 recommendations : 3 • Avoiding or mitigating impacts on environmental 4 resources identified as sensitive to Project-related 5 disturbance. 6 • Addressing site-specific mitigation that is required 7 by the agencies to meet the stipulation (s) of 8 approval . 9 • Developing mitigation that meets the requirements for 10 the issuance of the Notice to Proceed ("NTPs") , as 11 described in the BLM Right of Way ("ROW") grant. 12 These protections and commitments have been 13 incorporated into the Plan of Development which is 14 currently being reviewed by the agencies for their final 15 approval prior to construction. The BLM' s Plan of 16 Development ("POD") is expected to be finalized in 2027 . 17 Q. What easements are required for the Project? 18 A. New permanent and temporary land rights are 19 required for the transmission line facilities, primarily for the 20 transmission line corridor, access roads, and work areas . The 21 Project will be located on federal land managed by the BLM and VAIL, DI - 14 Rocky Mountain Power 1 the Bureau of Reclamation ("BOR") , state lands managed by the 2 Idaho Department of Lands, and private lands .2 3 The Parties were granted a permanent 250-foot-wide ROW 4 for the Project and associated on and off ROW access roads 5 across federal lands in 1979 and amended in 2018 . The Companies 6 are currently working with the Idaho Department of State Lands 7 to acquire appropriate easements across state lands for 8 permanent Project facilities prior to construction. 9 The Parties are actively working with private landowners 10 to obtain the necessary easements . 11 Existing utilities, including railroads will be crossed 12 by the Project and may also require approvals and/or easements . 13 The Parties have identified these facilities, their owners, and 14 are working with them to obtain the necessary approvals . 15 Q. Can you generally discuss the permitting activities 16 efforts led by PacifiCorp? 17 A. The Company is working through all the necessary 18 permits and rights of way for the Gateway West Segment E-8 19 transmission project. As a part of the permitting process, the 20 Parties have held eight (8) public open house events and three 21 (3) neighborhood meetings to date. Ten of these meetings were 22 held in-person at various locations near the Segment E-8 route, 23 and one virtual meeting was made available for those unable to 2 The BOR has delegated full administrative responsibility of BOR-administered lands to the BLM based on coordination with BOR under a 1982 Interagency Agreement. VAIL, DI - 15 Rocky Mountain Power 1 attend on site. Three additional neighborhood meetings are 2 planned in accordance with the conditional use permit 3 applications . Stakeholder briefings have been held with Ada 4 County, Canyon County, Elmore County, Gooding County, Jerome 5 County, Lincoln County, and Owyhee County, as well as with the 6 Idaho Office of the Lieutenant Governor, the Magic Valley 7 Congressional District, and the Boise Congressional District . 8 The project has been discussed and reviewed with the 9 Idaho Fish and Game, the Office of Energy and Mineral 10 Resources/Office of Species Conservation, the Idaho State 11 Historic Preservation Office, the Idaho National Guard, Idaho 12 Food Producers, Idaho Department of Lands, Idaho State 13 Department of Agriculture, and the Idaho Department of Parks and 14 Recreation. A list of regulatory permits and land use approvals 15 that were necessary for the transmission line, along with their 16 status as of March 25, 2026, is included as Exhibit No. 4 . 17 Q. When do you anticipate PacifiCorp' s 18 responsibilities for the Project will be complete? 19 A. Idaho Power is expected to take over as 20 construction project manager in late 2026 or 2027 . The Company 21 will continue to be engaged in the Project through a future 22 Construction Funding Agreement. 23 VAIL, DI - 16 Rocky Mountain Power 1 V. CONCLUSION 2 Q. Please summarize your recommendation to the 3 Commission. 4 A. GWWE-8 will provide substantial benefits to Idaho 5 Power and PacifiCorp customers, the line is necessary, and in 6 the public interest. Based on these conclusions, I recommend 7 that the Commission grant Idaho Power and PacifiCorp each a 8 CPCN, to ensure Idaho Power may begin timely construction of the 9 line and maintain the expected energization of the first section 10 of the line in late 2028 . 11 Q. Does this conclude your direct testimony? 12 A. Yes . 13 VAIL, DI - 17 Rocky Mountain Power 1 DECLARATION OF RICK A. VAIL 2 I, Rick Vail, declare under penalty of perjury under 3 the laws of the state of Idaho: 4 1 . My name is Rick Vail . I am employed by Rocky 5 Mountain Power as the Vice President of Transmission. 6 2 . On behalf of Rocky Mountain Power, I present 7 this pre-filed direct testimony in this matter. 8 3 . To the best of my knowledge, my pre-filed 9 direct testimony and Exhibit No. 4 is true and accurate . 10 I hereby declare that the above statement is true to 11 the best of my knowledge and belief, and that I understand 12 it is made for use as evidence before the Idaho Public 13 Utilities Commission and is subject to penalty for perjury. 14 SIGNED this 3rd day of April 2026, at Portland, 15 Oregon. 16 17 Signed.- 18 Rick A. Vail 19 20 21 22 23 24 25 26 27 28 29 30 VAIL, DI - 18 Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-26-09 IDAHO POWER COMPANY VAIL, DI TESTIMONY EXHIBIT NO. 4 Action Requiring Agency Permit,License, Relevant Laws and Status/Estimated Permit,Approval,or Compliance,or Review Regulations Timeline to Obtain Review FEDERAL Locating Facilities on Land under Federal Management Compliance with BLM Final Supplemental CEQ 40 CFR 1500 Final SEIS-2017, NEPA Environmental Impact ROD 2017 Statement and Record of Decision Preconstruction BLM ROW grant(An agency- FLPMA of 1976(Public ROW Grant-July surveys and reports; approved POD is Law[PL] 94-579);43 27,2017 geotechnical studies; required prior to United States Code construction, initiating any (USC) 1761 et seq.;43 POD and operation, construction or other CFR 2800 Preconstruction maintenance surface disturbing Surveys—Q2 2026 activities) Biological Resources Protection of USFWS Compliance;Migratory Migratory Bird Treaty POD and migratory birds Bird Mitigation Memo Act(16 USC 703 et Preconstruction seq.);50 CFR 1 Surveys—Q1 2027 Protection of bald and USFWS Compliance Bald and Golden Eagle golden eagles Protection Act of 1972 (16 USC 668) Protection of special- BLM Compliance BLM Policy Manual status species 6840;Forest Service Manual 2670;individual agency guidance Protection of fish, BLM Compliance BLM Policy Manuals wildlife,and aquatic 6500 and 6720 resources Exhibit No.4 Case Nos. IPC-E-26-09&PAC-E-26-06 R.Vail,PAC Page 1 of 6 Action Requiring Agency Permit,License, Relevant Laws and Status/Estimated Permit,Approval,or Compliance,or Review Regulations Timeline to Obtain Review FEDERAL Discharge of dredge or USACE Section 404 permit CWA(33 USC 1344); Q 12027 fill material into (coverage under waters of the U.S., nationwide permit) including wetlands Placement of USACE Section 10 permit Rivers and Harbors Act Q1 2027 structures and of 1899(33 USC 403) construction work in navigable waters of the U.S. Cultural Resources Disturbance of historic Federal lead Section 106 consultation NHPA(54 USC 306108; Commitments to properties agency, State 36 CFR 800) protect cultural, Historic historic and tribal Preservation resources are Office,Advisory included in POD Council on Historic Preservation Surveys are well Potential conflicts with Federal lead Consultation with American Indian underway;The freedom to practice agency,federal affected American Religious Freedom Act Companies will traditional American land management Indians of 1978(42 USC 1996); obtain to complete Indian religions agency Religious Freedom needed treatment Restoration Act of 1993 activities prior to (PL 101-141) construction.During construction Disturbance of graves, Federal land Consultation with Native American Graves Contractor will be associated funerary management affected American Protection and responsible to obtain objects,sacred objects, agency Indian groups regarding Repatriation Act of 1990 if needed. and items of cultural treatment of remains and (25 USC 3001-3002) patrimony obj ects Investigation of Affected land State and federal permits Section 106 cultural resources management for study of historical Consultation,National agency and archaeological Preservation Act resources Excavation of Affected land Antiquities and Cultural Archaeological archaeological management Resource Use Permit Resources Protection Act resources agency of 1979(16 USC 470aa to 470ee); Protection of Affected land Compliance National Trails System segments,sites,and management Act of 1968(PL 90- features related to agency 543); 16 USC 1241 et National Trails seq. Exhibit No.4 Case Nos. IPC-E-26-09&PAC-E-26-06 R.Vail,PAC Page 2 of 6 Action Requiring Agency Permit,License, Relevant Laws and Status/Estimated Permit,Approval,or Compliance,or Review Regulations Timeline to Obtain Review FEDERAL Paleontological Resources Surface disturbance on BLM and BOR Compliance with BLM 40 CFR 1500-1508; Included in POD federal land or federal and BOR mitigation and FLPMA(43 USC 1701 aid project planning standards for et seq.);36 CFR 291; paleontological BLM Handbook H- resources of public lands 8270;BLM Manual 8270 Collection of BLM and BOR Permit to collect Paleontological Surveys are well paleontological paleontological Resources Preservation underway;The resources from federal resources from federal Act of 2009(16 USC Companies will land lands 470aaa.);FLPMA of obtain to complete 1976;BLM Handbooks needed treatment H-8270 and 8270-1 activities prior to construction. During construction Contractor will be responsible to obtain if needed. Air Traffic Location of towers and Federal Aviation File Notice of Proposed Federal Aviation Act of The Companies spans in relation to Administration Construction or 1958(PL 85-726); 14 will obtain prior to airport facilities and Alteration;Federal CFR 77 construction—Q2 airspace Aviation Administration 2027 to determine if structure is No Hazard Exhibit No.4 Case Nos. IPC-E-26-09&PAC-E-26-06 R.Vail,PAC Page 3 of 6 Action Requiring Agency Permit,License, Relevant Laws and Status/Estimated Permit,Approval,or Compliance,or Review Regulations Timeline to Obtain Review STATE OF IDAHO Surface Disturbance and Water Quality Degradation Construction sites Idaho Department Section 401 Water Idaho Administrative The Companies will with greater than 1 of Environmental Quality Certification, Code(IAC)58.01.25 obtain prior to acre of land disturbed Quality(IDEQ) Idaho Pollution construction—Q2 Discharge Elimination, 2027 Large Construction General Permit,and Stormwater Pollution Prevention Plan Consider alteration of Idaho Department Stream Channel IS 42-3804;IAC The Companies will any stream channel or of Water Resources Alteration Permit and 37.03.07 obtain prior to wetland. Wetland Removal Fill construction—Q2 Permit 2027 Air Quality Construction Air Quality Consultation with IDEQ IAC 58.01.01 Construction Division,IDEQ for compliance with Contractor will Construction General obtain prior to Emission Standards construction—Q4 2027 State Lands Crossing easement Idaho Department Non-roadway easement IAC 20.03.08 The Companies will of Lands and temporary use obtain necessary permit for crossing easements prior to state-administered land construction—Q2 2027 Utility Crossing easements Idaho Utility permit,oversize — The Companies will Transportation permit(self-issuing) obtain necessary Department easements prior to construction—Q2 2027 Exhibit No.4 Case Nos. IPC-E-26-09&PAC-E-26-06 R.Vail,PAC Page 4 of 6 Action Requiring Agency Permit,License, Relevant Laws and Status/Estimated Permit,Approval,or Compliance,or Review Regulations Timeline to Obtain Review STATE OF IDAHO Greater Sage-Grouse Requires that all All state agencies Compliance with EO State of Wyoming EO Included in POD— agencies demonstrate 2019-3 2015-4 Q4 2026 that activity proposed for permitting be compliant with the requirements of the EO in greater sage-grouse core areas Biological Resources Habitat modification Idaho Department Potential project impacts Endangered Species Surveys are well of Fish and Game to fish and wildlife Act(16 USC 1531 et underway—Q1 species and their habitat seq.);IAC 2027 13.01.06.150 State-listed Noxious Weeds and Other Invasive Plant Species Construction and Idaho State Compliance IS 22-2407 Surveys are well operation activities Department of underway—Q1 Agriculture 2027 Pesticide use Idaho State Compliance IS 22-2407 Permits will be Department of obtained prior to Agriculture use,if needed Paleontological Resources Collection of Idaho State Permit to collect IS 67-4120 The Companies will paleontological Historical Society paleontological resources obtain to complete resources from state from state lands needed treatment lands activities prior to construction. During construction Contractor will be responsible to obtain if needed. Exhibit No.4 Case Nos. IPC-E-26-09&PAC-E-26-06 R.Vail,PAC Page 5 of 6 Action Requiring Agency Permit,License, Relevant Laws and Status/Estimated Permit,Approval,or Compliance,or Review Regulations Timeline to Obtain Review STATE OF IDAHO Local and County Conditional Use Ada County, Consider issuance of — The Companies are Permits Idaho;Elmore conditional use permits for preparing County,Idaho construction of applications—Q4 transmission line(varies 2026 by county). Special Use Permits Gooding Consider issuance of — The Companies are County,Idaho; special use permits for preparing Jerome County, construction of applications—Q1 Idaho transmission line(varies 2027 by county). Temporary Use Planning Consider issuance of a — Construction Permit,Grading Department building permit or a Contractor will Permit Temporary Use Permit for obtain prior to material and contractor construction yards and a grading permit for noxious weed control coordination. Encroachment Permit Public Works Consider issuance of an — Construction Department encroachment permit for Contractor will new access roads where obtain prior to they intersect with existing construction county roads. Road Crossing Permit, Public Works Consider issuance of road — Construction Road Maintenance Department crossing permit Contractor will Agreement obtain prior to and road maintenance construction agreement for overhead transmission line. Exhibit No.4 Case Nos. IPC-E-26-09&PAC-E-26-06 R.Vail,PAC Page 6 of 6