20170217IPC to Staff 1-12.pdf

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An IDACORP Company
DONOVAN E. WALKER
Lead Counsel
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February 17,2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-16-28
Certificate of Public Convenience and Necessity for Wood River Valley
Idaho Power Company's Response to the First Production Request of the
Commission Staff
Dear Ms. Hanian
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the First Production Request of the Commission
Staff.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to Staffs production requests.
Very urs,
ovan E. Walker
DEW:csb
Enclosures
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY TO CONSTRUCT
SYSTEM IMPROVEMENTS FOR WOOD
RIVER VALLEY CUSTOMERS
CASE NO. |PC-E-16-28
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
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COMES NOW, ldaho Power Company ("ldaho Power" or "Compa[V"), and in
response to the First Production Request of the Commission Staff ("Staff') to ldaho
Power Company dated January 27 ,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCT]ON REOUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 1: The Application indicates that the Company determined that
the Overhead Transmission options are not viable. Application at 19-20, Angel! Direct
at 29-31. For the Dollar Mountain route, this determination was based on likely
opposition, lack of redundancy, and need for condemnation. Angell Direct at 29. For
the Downtown District route, this determination was based on likely opposition, likely
failure to receive permitting from the City of Ketchum, and on geographical constraints,
and likely need for significant condemnation of private property. Application at 19-20,
Angell Direct at 30-31. The Application indicates that the Overhead Distribution option
is now considered the base case option. Application at21-22.
a) Please provide additional detail regarding the determinations that the
Overhead Transmission options are not viable and why and how they were made.
Please include any documentation of the decisions and any information, studies or
analysis on which the determinations were based.
b) When were the Overhead Transmission options determined to not be
viable? Please provide any documentation.
c) Please provide the Company's criteria for deciding that condemnation of
private property makes a project unviable and how were such criteria applied here.
Have these same criteria been applied to other ldaho Power projects?
d) Please provide the Company's criteria for determining that visual impact
and loca! customer opposition makes a project unviable and how were such criteria
applied here. Have these same criteria been applied to other ldaho Power projects?
e) Please provide details and documentation regarding when and why the
Overhead Distribution option became the base case option, including any studies or
analyses.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
f) Please describe and provide documentation of the differences between
the Overhead Transmission and Overhead Distribution options described in the
Application at 19-22, including but not limited to any differences in cost,
feasibi lity/viability, req u ired eq uipment, and reliability.
g) Has the Company's proposed base case using Overhead Distribution ties
been the subject of either the Company's Community Advisory Committee (CAC)
process, or any other public forum? lf so, please provide a summary of the proceedings
and meeting minutes.
RESPONSE TO REQUEST NO. 1:
a) The viability of constructing a second overhead transmission line between
the Wood River and Ketchum substations came into question at the beginning of the
ldaho Power 2OO7 CAC process. Two of the three CAC mapping groups only proposed
underground transmission options within the Ketchum city limits. The third mapping
group proposed underground contingent on funding. The Downtown route was initially
deemed not viable at that time and reaffirmed in2011. ln the summer of 2016, ldaho
Power performed a second review of that route. At that time, for reasons noted in ldaho
Power's Application, ldaho Power determined that it was not a viable route. Please also
see the additional discussion and materials provided in response to subparts b through f
of this Request.
Based on the discussions during public meetings in 2014, CAC members and
ldaho Power became increasingly concerned about the viability of the Dollar Mountain
route. The routing investigation of that option resulted in the joining of the two
transmission lines on single towers across Dollar Mountain. ldaho Power's Planning
Department determined that placing the two transmission circuits on common towers
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
across Dollar Mountain was not acceptable because a common tower section of the
overhead transmission across the top of Dollar Mountain presents the North Valley with
continued exposure to sustained outages for tower or hardware failures. This common
circuit outage exposure does not meet the project purpose.
b) ln the summer of 2015, after a review by ldaho Power's Planning
Department, ldaho Power determined that double circuiting the transmission line across
Dollar Mountain was not acceptable as described in the Company's response to Staffs
Request No. 1.a.
The Downtown route was initially deemed not viable during the original meetings
of the CAC in 2007 and reaffirmed in 2011. !n the summer of 2016, ldaho Power
performed an additional review of that route. At that time, for reasons noted in ldaho
Power's Application, ldaho Power determined that it was not a viable route.
c) ldaho Power generally attempts to avoid condemnation by taking part in
negotiated resolutions, to the extent possible. Given the myriad of potential legal and
public relations issues involved in condemnation, it is not practical to have a one-size
fits all criteria. That said, ldaho Power typically reviews the following considerations
when evaluating the potential impacts of condemnation on a transmission line route:
the size and scope of required condemnation, the cost of condemnation, the time frame
related to condemnation proceedings, the impact to landowners, the impact to customer
satisfaction, the impact on local project support and permitting approvals, environmental
issues, and alternatives to condemnation. ln this case, ldaho Power believed that the
cost to condemn property in downtown Ketchum could be significant given property
values. !n addition, ldaho Power was advised by the CAC and other members of the
community that the legal proceedings for such action would be significant because
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
residents and public officials were adamantly against having transmission lines through
downtown Ketchum. Finally, the cities of Ketchum and Sun Valley have ordinances that
require new transmission facilities to be located underground. While any one of these
factors (by themselves) may not prevent condemnation, when reviewed in totality, ldaho
Power believed that other options were preferred.
d) Like with condemnation, the determination of whether visual impacts
preclude a project requires a case-by-case analysis. No single set of criteria is used for
this evaluation. Visual impacts alone generally do not prevent a project from being built.
However, visual impacts-coupled with condemnation issues, restricting ordinances,
and congested valley conditions-can lead ldaho Power to move away from a particular
option. ln this case, when these issues were reviewed in totality, the CAC and ldaho
Power determined that the Downtown route would likely not be built.
e) The Overhead Distribution option became the base case option in a letter
sent on July 6, 2015, to the Wood River CAC members. Please see Attachment 1
provided on the enclosed CD. The letter states that the Overhead Distribution option
should be used as the reference base cost when determining the incrementa! cost to be
funded by the local community.
The analysis performed to determine that the Overhead Distribution option was
the base case option was included in the testimonies of Company witnesses Angell at
29 and Adelman at 18.
The Company has typically relied on redundant overhead transmission for full
redundancy of service. The other traditional construction practice that the Company
utilizes to provide redundancy of service is overhead distribution. The Company
regularly installs tie switches between distribution circuits to provide alternate service to
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
restore customers during substation and circuit outages. The Overhead Distribution
option was determined to be more viable than overhead transmission and was used as
the base cost.
0 The Overhead Transmission option estimate is $18.5 million, not including
any right-of-way costs. Please see Attachment 2 provided on the enclosed CD. The
Overhead Distribution option estimates range between $29.1 million to $31.1 million.
Please see Attachments 3-6 provided on the enclosed CD, which include cost estimates
for the projects that encompass the Overhead Distribution option and supporting notes.
ldaho Power's Application (p. 19) references the feasibility/viability problems with
an Overhead Transmission route, either across Dollar Mountain or through the Ketchum
downtown district. Generally, the Dollar Mountain option does not meet the intended
purpose, providing a fully redundant line, while the downtown route has constructability
challenges with zerc setback buildings and tight geographical constraints. The
feasibility/viability of the Overhead Distribution option is described in the Company's
Application (pp. 21-22) and is a traditiona! and standard construction.
The required equipment is the same for the Common Route (Angell Direct p. 25).
From this point, the required equipment is substantially different between the two
options. An Overhead Transmission option, similar to Underground Transmission,
requires switches and terminals within the Ketchum substation. The Overhead
Distribution option requires a new substation, explained in the Application (p. 21),
including transformers, metalclad, getaway feeders, a control building, and visual/sound
screening.
Reliability is discussed in detail in Adelman Direct (pp. 6-9). A transmission
alternative, overhead or underground, provides up to 120 megawatts ("MW") of
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
capacity, while a distribution alternative provides 60 MW of capacity. A transmission
alternative is fully redundant and customers would likely not experience sustained
outage for loss of a transmission line. A distribution alternative may have some
interruption in service caused by a transmission line; customers may experience short
sustained outages while the distribution circuits are switched.
g) Yes. The Overhead Distribution option was first presented as an
alternative at the October 2,2014, CAC meeting (please see Attachments 7 [meeting
results rather than meeting minutesl and 8 provided on the enclosed CD). The CAC did
not select this option as the preferred alternative, but it was identified as a feasible
alternative for further evaluation.
The Overhead Distribution option was presented again as background
information in the October 30,2014, CAC meeting to compare with the Underground
Distribution option (please see Attachment 9 [meeting notes] provided on the enclosed
cD).
ln a July 2015 letter to the CAC, the Overhead Distribution construction method
was mentioned as the base case when determining the incremental costs to be funded
by the local community (please see Attachment 1 provided on the enclosed CD).
The response to this Request is sponsored by Dave Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
REQUEST NO. 2: Please provide the Company's cost estimates for the
Overhead Transmission-Downtown District route (Application at 19; Angell Direct at26-
27\. Please include electronic workpapers with allformulas and links intact.
RESPONSE TO REQUEST NO. 2: A high-level estimate was developed for the
Overhead Transmission-Downtown District route. The estimate is approximately $18.5
million. Please see Attachments 2 and 6 provided with the Company's response to
Staffs Request No. 1.f. However, the estimate does not include any right-of-way
acquisition costs. The design work and estimate for this option were not carried fonrard
for the reasons described in Angell Direct (p. 29).
The response to this Request is sponsored by Ryan Adelman, Customer
Operations Projects Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. S
REQUEST NO. 3: Please describe the equipment required for the Overhead
Transmission-Downtown District route (Application at 19; Angell Direct at26-27).
a) PIease include the quantities, types, and ratings of transformers, poles,
and conductors considered in its cost estimates for this option.
b) Please provide the Company's estimate of the load that the Overhead
Transmission Downtown District route could serve in the event that the Company's
existing transmission line were to fail completely.
RESPONSE TO REQUEST NO. 3:
a) A preliminary route investigation determined there would be an estimated
18 custom, self-supporting, steel mono-pole transmission structures with concrete pier
foundations, 16,000 feet of 397 thousand circular mils ("kcmil") aluminum-conductor,
steel-reinforced ('ACSR") cable and fifty-four 138 kilovolt ('kV") class post insulators
with extension arms on corner structures. No additional transformers are required for
this option.
b) The route, if built with a 397 kcmi! ACSR conductor as proposed for the
common overhead section, could serve up to 144.6 MW of load in the summer or 206
MW in the winter, assuming a delivery voltage of 138 kV and unity power factor.
The response to this Request is sponsored by Ryan Adelman, Customer
Operations Projects Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
REQUEST NO. 4: Please describe the equipment required for the Underground
Transmission/TPl option (Application at 20; Angell Direct at27).
a) Please include the quantities, types, and ratings of transformers, and
conductors considered in its cost estimates for this option.
b) Please describe construction of the underground installation, including
installation depth, splice vaults/and access points, trenches, and duct banks.
c) Please provide the Company's estimate of the load that the Underground
Transmission/TPl option could serve in the event that the Company's existing
transmission Iine were to fail completely.
RESPONSE TO REQUEST NO. 4:
a) From the transition point, continuing to Ketchum substation, the
underground conductor will be three individual 750 kcmil copper cables with 138 kV
insulation. The cables will be approximately 2.1 miles long, with a combined capacity of
120 MVA. At Ketchum substation, the underground cable will connect to the existing
138 kV bus; therefore, no new investment in transformers is necessary. Each
substation will include switches and terminals to isolate the line.
b) The cable trench will be approximately three feet wide by six feet deep
and contain the three transmission cables, each in its own conduit, and a fiber optic
cable for communication. A majority of the cable trench will be located in road right-of-
way, and the trench will be concrete encased. A splice vault will be installed
approximately every 2500 feet. These vaults are approximately 20 feet long, eight feet
wide, and eight feet deep. ldaho Power will pursue private easements for these vaults
to allow for adequate access with minimal traffic disturbance.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1O
c) The Underground TransmissionffPl option could serve 120 MW of load,
assuming a delivery voltage of 138 kV and unity power factor.
The response to this Request is sponsored by Ryan Adelman, Customer
Operations Projects Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
REQUEST NO. 5: ln his direct testimony, Mr. Adelman indicates that Idaho
Power has no experience with underground transmission lines, and that in the event of
a cable failure, the Company would use contractors with underground transmission
experience (Adelman Direct at7).
a) Please provide a list of qualified contractors and where they are located.
b) Does the Company plan to enter into agreements with these companies to
ensure that service is available when required? Please describe the type of agreement
and services required.
RESPONSE TO REQUEST NO. 5:
a) ldaho Power does not currently have a list of qualified contractors.
b) Idaho Power would select a cable manufacturer and use a contractor that
is certified by that manufacturer to install, splice, and terminate its specific cable. ldaho
Power will specify a warranty or agreement with the selected manufacturer so that, in
case of a failure, the manufacturer would supply a qualified contractor to make the
repair.
The response to this Request is sponsored by Ryan Adelman, Customer
Operations Projects Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 12
REQUEST NO. 6: Has the Company compared the lifecycle costs of maintaining
the proposed TP1 Underground Transmission System and the Overhead Transmission
system described on page 19 of the Company's Application? lf so please provide such
information.
RESPONSE TO REQUEST NO. 6: The annual operations and maintenance
costs, expressed in 2016 dollars, for Underground Transmission and Overhead
Transmission are $26,558 and $13,124, respectively. An overhead transmission line
typically has a lifespan of 70 to 80 years, while underground transmission lines of the
proposed design have only been around for 30 to 40 years and have not typically
reached end of life. Therefore, a full maintenance lifecycle cost analysis including the
replacement of the asset has not been completed.
The response to this Request is sponsored by Dave Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
REQUEST NO. 7: Please provide any additional analysis or work in conjunction
with INL regarding locally sited generation resources that is not included in Exhibit No.
3.
RESPONSE TO REQUEST NO. 7: Kurt Myers, Group Lead Business
Development Lead - Renewable Energy, at the ldaho National Laboratory provided
feedback on the costs and simulation. His comments on the installed resource cost
were: that a diesel reciprocating engine is in the range of $750 to $1,000 per kilowatt
("kW"), a zinc-ion battery is about $800 per kilowatt-hour, and a natural gas turbine is
$1,500 per kW. Please see the cost worksheet provided on the enclosed CD.
Mr. Myers also recommended the following simulations adjustments: the fuel
prices should be adjusted, in order to connect solar PV to the AC system the check box
indicating a dedicated converter is required, force the simulation to use solar PV LCOE,
and combine generators to speed up the simulation time.
The response to this Request is sponsored by Dave Angell, Customer
Operations Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
REQUEST NO. 8: The Company's Application, at 16, states that the expected
duration of sustained outages will be more than 209 minutes per year with the current
transmission configuration. Please provide information on sustained outages occurring
over the previous 36 months including duration, likely cause, and number of customers
affected.
RESPONSE TO REQUEST NO. 8: The followin g table provides the requested
outage information
Date
Duration
(minutes)
Customerc
Affected Likelv Cause
614/2OL4 46 20,228 Equipment Failure - Broken Cross-Arms
8/t2/2O14 L26 9,016 Lightning
LO/73lzOLs 465 7,73t Maintenance - Repair Woodpecker Damage
The response to this Request is sponsored by Dave Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
REQUEST NO. 9: The Company describes the activities in 2014 of the
"updated" CAC (Application at 9; Angell Direct at 13-14). Please describe the
recommendations of the updated CAC and dates that these recommendations were
made.
RESPONSE TO REQUEST NO. 9:At the conclusion of the October 2,2014,
meeting, the CAC recommended that New IPCO Option #2 (100 percent Historical Peak
Backup with underground distribution) and New IPCO Option #4 (100 percent of
Historical Peak Backup with overhead distribution) be further refined. New IPCO Option
#2 was identified as the new preferred alternative and the New IPCO Option #4 was
considered the third alternative. The second alternative identified was the proposed
138 kV redundant line with overhead and underground sections.
At the conclusion of the October 30, 2014, meeting, the CAC reached a
consensus to support New IPCO Option #2 as its sole recommendation. Please see
Attachment 9 provided with the Company's response to Staffs Request No.1.g.
The response to this Request is sponsored by Dave Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 16
REQUEST NO. 10: What are the ages of the poles and any other equipment
located on the existing distribution line running parallel to Highway 75 that would be
replaced by transmission poles and other equipment under the Company's proposal for
the Common Route?
RESPONSE TO REQUEST NO. 10: Approximately 50 percent of the poles and
equipment along Buttercup Road were installed in 1976, and the other half installed in
1997 (approximately 1.6 total miles in this section). Approximately 75 percent of the
poles and equipment along State Highway 75 between Buttercup Road and East Fork
Road were installed in 1991, and the other 25 percent were installed in 1997
(approximately 2.9 total miles in this section). Approximately 25 percent of the poles
and equipment along State Highway 75 from East Fork Road to the end of the Common
Route were installed in 1992, and the other 75 percent were installed in 2013
(approximately 3.0 total miles in this section).
When rebuilding, the existing poles, cross-arms, and insulators would all be
replaced with new poles, cross-arms, and insulators. The distribution conductor would
remain and be transferred to the new poles. Approximately 50 percent of the equipment
would remain, and the other 50 percent would be replaced with new equipment, with the
old equipment being recycled back into inventory. Equipment generally includes pole-
top transformers, switches, fuses, reclosers, and voltage regulators.
The response to this Request is sponsored by Ryan Adelman, Customer
Operations Projects Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 17
REQUEST NO. 11: The Com pany explains that it "generally initiates and
constructs a second transmission source and transformer when a substation peak load
is projected to exceed 40 MW." Application at 15.
a) Please provide any documentation of this policy/4O MW criterion and how
it has been applied.
b) How did the Company derive its 40 MW criterion?
c) Do any other power companies in the United States use similar criteria? lf
so, please provide examples.
RESPONSE TO REQUEST NO. 11:
a) No written documentation exists for this Company guideline. However, as
described in Staffs Request 11.b below, the 40 MW guideline is used on the design
specifications of the Company's typical distribution substation. lt has recently been
applied at the Victory substation south of Boise and at the McCall substation in McCall,
ldaho. The Company is also moving forward with a second transmission project in the
Eagle and Star area based on this guideline.
b) The 40 MW guideline is one component of the Company's electrical
service plan as described during the CAC process. A typical distribution substation,
when completely built-out, is designed to serve 80 MW of peak load with two 44.8 MVA
transformers and eight 10 MVA distribution circuits. This two-transformer design allows
the Company to more quickly restore customers by switching them to the second
transformer when an outage occurs on one transformer. The Company is able to make
use of this alternate transformer restoration to restore customers during a majority of the
year. Transmission lines have more exposure to outage conditions than transformers;
thus, this restoration design practice is extended to the transmission lines that source
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 18
the substation. Therefore, when load at a substation is projected to exceed 40 MW, a
second transformer and transmission source is added.
c) Reliability criteria are often based on a number of different factors,
including exposure to outage conditions, number of customers impacted, condition of
existing infrastructure, and the costs of the infrastructure addition. These criteria and
practices vary between utilities.
The response to this Request is sponsored by Dave Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 19
REQUEST NO. 12: The Company explains that reconstructing the existing
transmission line would entail numerous interruptions to service, and would therefore
not be feasible. Application at 16-17. Did the Company consider the option of
constructing a replacement transmission line parallel to the existing transmission line,
using the existing route and right-of-way, and keeping the existing line in-service during
construction, as an alternative to the Company's proposal or service interruption during
transmission line reconstruction? lf so, please provide the Company's analysis and cost
estimates. lf not, why not?
RESPONSE TO REQUEST NO. 12: Yes, the Company did consider
constructing a new transmission line parallel to the existing 138 kV line from Wood
River to Ketchum. The majority of the easements for the existing Wood River-Ketchum
138 kV line were acquired in 1962 and 1970 and are centerline only. The easements
do not specify an easement width. This lack of specificity means that any additional line
built on a separate and parallel alignment would require acquisition of new easements
for the new line. Residential development has occurred adjacent to a large portion of
the existing line (both sides) since it was constructed. This residential development
would preclude or cause difficulty in acquiring new easements for a parallel line. lt is
believed that there would be substantial opposition to right-of-way acquisition through
established residential developments. A parallel line using the existing route and right-
of-way would not be a viable, permanent, or redundant service option. Having a new
second transmission line immediately adjacent to the existing line would not achieve the
level of additional reliability that was being sought by having a second feed to the
Ketchum substation. This is because a single event (such as an avalanche, wildfire,
localized ice events, or micro-burst winds) could cause both lines to fail at the same
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 20
time and still leave the north end of the Wood River Valley with no source of electrical
power. These two factors were the drivers in the Company's dismissa! of a parallel
transmission line as an option.
The response to this Request is sponsored by Ryan Adelman, Gustomer
Operations Projects Manager, ldaho Power Company.
DATED at Boise, ldaho, this 17th day of February 2017.
E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 21
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 17th day of February 2017 | served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Camille Christen
Deputy Attorneys General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
ldaho Gonseruation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
Zach Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michae! Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Kiki Leslie A. Tidwell
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
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camille.christen ouc.idaho.oov
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.22
Kiki Leslie A. Tidwell
300 Let'er Buck Road
Hailey, ldaho 83333
City of Ketchum
Matthew A. Johnson
Wm. F. Gigray, lll
WHITE PETERSON GIGRAY
& NICHOLS, P.A.
5700 East Franklin Road, Suite 200
Nampa, ldaho 83687
lndividual
Laura Midgley
231 Valley Club Drive
Hailey, ldaho 83333
Comcox, LLC
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
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Christa Bearry, Legal Assistant
]DAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 23