20170210Tidwell 1-35 to IPC.pdf

Peter J. Richardson (ISB No. 3195)
Greg Adams (ISB 7454)
Richardson Adams, PLLC
515 N. 2ih Street
P.O. Box 7218
Boise, Idaho 83 702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Kiki Leslie A. Tidwell
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA TIER 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. IPC-E-16-28
FIRST PRODUCTION REQUEST OF
KIKI LESLIE A. TIDWELL TO
IDAHO POWER COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), Kike Leslie A. Tidwell by and through her attorney of record, Peter J.
Richardson, hereby requests that Idaho Power Company ("Company") provide the following
documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplementary responses additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional to Ms. Tidwell at 300
Let 'er Buck Road, Hailey, Idaho 83333 [e-mail].
Tidwell First Production Request -IPC-E-16-07 1
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
If some of the following requests include disclosures deemed by Idaho Power to be
confidential, the ICIP has already entered into Idaho Power's standard confidentiality agreement.
REQUEST FOR PRODUCTION NO. 1
Please provide all of the Company's discovery responses to all other parties regardless of
whether said requests for discovery were formal or informal.
REQUEST FOR PRODUCTION NO. 2
The Company's Application provides at page 2 that "The North Valley is currently
supplied by a single-source radial line that has experienced sustained outages line events, which
Idaho Power forecasts to increase in frequency." With regard to this statement please respond to
the following requests:
A.) Please provide a map of the North Valley, including its electrical system.
B) Please define the term "sustained outage line events."
C) Please provide a complete list of the "experienced sustained outage line events" for
the line referred to. Include the duration, cause, remediation efforts and results, and cost for the
same.
D) When the line in question experiences a "sustained outage" event, please explain what
electrical service is available to the North Valley. Provide an electrical map showing the source
and routes for said residual electrical service.
E) Please provide copies of all "forecasts" referred to in the quoted passage from the
Company's Application. For each forecast please identify the individual(s) who prepared the
same and provide all workpapers and supporting documentation used in the preparation of each
Tidwell First Production Request-IPC-E-16-28. 2
forecast.
REQUEST FOR PRODUCTION NO. 3
The Company's Application provides at page three that, "Additionally, the existing radial
transmission line, constructed in 1962, is aged and must be reconstructed. The proposed
facilities will follow the same path ... " Please explain, in detail how the "proposed facilities will
follow the same path" and specifically identify the path referred to.
REQUEST FOR PRODUCTION NO. 4
Footnote 1, on page 3 of the Application states that Idaho Power was granted a CPCN for
a second 138 kV line in 1973 and references Case No. U-1006-89. Please provide all pleadings
from Case No. U-1006-89 and all other materials associated with Case No. U-1006-89 in the
Company's possession, including discovery responses and requests (both formal and informal),
public comments and internal company documentation (including Board of Director materials
and resolutions and minutes) in any way related to Case U-1006-89.
REQUEST FOR PRODUCTION NO. 5
Please reconcile the statement in the Company's Application that the Company "has
planned a second transmission line to the North Valley since 1973" [page 3] with the
Commission's findings on page 2 of Order No. 26107 in Case No. IC-E-95-6 that, "Because the
project, the Company concludes, is neither needed nor feasible, the Company requests authority
to amend [its CPCN] by removing the language authorizing the construction by Idaho Power of a
second Wood River/Ketchum 138 kV transmission line."
Please provide all material in the Company's possession related to, supporting, or
documenting the Commission's finding in 1995 that the second Wood River/Ketchum 138 kV
transmission line is neither needed nor feasible.
Tidwell First Production Request-IPC-E-16-28. 3
REQUEST FOR PRODUCTION NO. 6
Please provide all pleadings from Case No. IPC-E-95-6 and all other materials associated
with Case No. IPC-E-95-6 in the Company's possession, including discovery responses and
requests (both formal and informal), public comments and internal company documentation,
memoranda, notes etc (including Board of Director materials and resolutions and minutes) in any
way related to IPC-E-95-6.
REQUEST FOR PRODUCTION NO. 7
The Company's Application at page 4 states that the North Valley peak demand reached
63 megawatts in 2007. Please provide documentation of the referenced peak demand. Also for
the time of the North Valley peak demand in 2007 please separately identify the peak demand at
the Ketchum Substation and the Sun Valley Substation. Please, for each year from 1973
forward, identify the North Valley peak demand and the peak demand for the Ketchum
Substation and the Sun Valley Substation at the time of the North Valley peak demand for each
year. Please also identify the peak demand and time of the peak demand for the Ketchum
substation and the Sun Valley substation for each year since 1973.
REQUEST OF PRODUCTION NO. 8
Please reconcile the assertion in the Company's Application at page 3 that there is a
"continuing need to serve growing load" with the fact asserted on page 4 of the Application that
the North Valley peak occurred a decade ago in 2007.
REQUEST FOR PRODUCTION NO. 9
Based on the assertion that peak load for the North Valley occurred ten years ago, please
explain and document the Company's understanding of the reasons for the declining peak load in
the North Valley.
Tidwell First Production Request-IPC-E-16-28. 4
REQUEST FOR PRODUCTION NO. 10
Please reconcile the assertion on page 4 of the Application that "peak demand reached 63
megawatts" in 2007, with the assertion on page 5 of the Application that the Ketchum and
Elkhorn substations' peak load is "about 60 MW."
REQUEST FOR PRODUCTION NO 11
What is the capacity of the current distribution line along State Highway 75 to provide
service to the North Valley? For example how much of the 63 MW (or 60 MW) of North Valley
peak demand could be served via the existing distribution line along State Highway 75? If the
existing transmission line to the North Valley was out of service please provide an explanation of
how that existing distribution line along State Highway 75 would function. Please provide a map
showing the area of the North Valley that would be without electric service if the existing
transmission line serving the North Valley were out of service.
REQUEST FOR PRODUCTION NO. 12
On page 4 of the Application the Company asserts that, "Access to repair the [ existing]
line is impeded by residential development, rough terrain, and aged construction roads in many
areas." Please provide a detailed map of the existing line that shows the points of access and
access roads for maintenance purposes. Please indicate on the map (a) where the residential
development impedes access, (b) where rough terrain impedes access and ( c) where aged
construction roads impede access. Please include a narrative explaining and documenting access
rights.
REQUEST FOR PRODUCTION NO. 13
At page 4 of the Application the Company asserts that, "This line's access limitations
may result in extended outages ... caused by, among other things, vandalism, inclement
Tidwell First Production Request-IPC-E-16-28. 5
weather, wood decay, woodpecker damage, avalanche, fire and micro-burst wind events."
Please provide the duration, cost of response/repair and the date of each extended outage on this
line caused by:
(a) vandalism
(b) inclement weather
(c) wood decay
(d) woodpecker damage
( e) avalanche
(f) fire
(g) micro-burst wind events
Please explain in detail, including itemized costs, and provide copies of all studies and
documentation all of the measures the Company has taken to anticipate and prevent the above
listed causes of outages on the identified line.
REQUEST FOR PRODUCTION NO. 14
Page 5 of the Company's Application states that, "Deep snow and steep terrain can create
very difficult access to susceptible sections of the existing transmission line ... " Please provide a
map indicating each "susceptible section" of the existing transmission line and a narrative
explanation as to why each identified section is so described.
REQUEST FOR PRODUCTION NO. 15
Please provide a map of the existing transmission line showing land ownership over
which the line traverses. Provide a copy of the easements for each parcel of land so identified.
REQUEST FOR PRODUCTION NO. 16
The Company's application provides at page 7, that "At the Company's request, the
Tidwell First Production Request-IPC-E-16-28. 6
Commission cancelled Certificate No. 272." Please provide a copy of all communications the
Company had with the Commission, including informal communications with its Staff and or
the Commissioners, regarding the Company's request to cancel Certificate No. 272. Please
provide all internal communications to the Company regarding cancellation of Certificate No.
272, please be sure to include all notes, memoranda and minutes of board meetings.
REQUEST FOR PRODUCTION NO. 17
On page 7 of the Company's Application is a list ofreasons for public opposition,
expressed in 1995, to the proposed second transmission line . Those reasons are "the difficulty
of finding an acceptable route ... aesthetic impacts, perceived health and safety concerns and
requirement oflocal funding of incremental cost of placing part or all of the line underground."
Please specifically identify (a) how the currently proposed route is different from the route
proposed in 1995, (b) how the aesthetic impacts are different from the proposed aesthetic
impacts of the proposed route in 1995, (c) how the perceived health and safety concerns are
different from the health and safety concerns expressed in 1995 and how the concerns of local
funding of incremental costs of placing part or all of the line underground are different from
those concerns expressed in 1995.
REQUEST FOR PRODUCTION NO. 18
In Order No. 26107, granting Idaho Power's Application to amend Certificate No. 272 to
delete the Commission's prior authorization to construct the second transmission line, the
Commission stated at pages 1 and 2:
Regarding reliability, Idaho Power reports that it has thoroughly reviewed the reliability
of its electric service to the Ketchum/Sun Valley area. The Wood River/Ketchum 138
kV transmission line, the Company contends, has had an excellent record of reliability
since its construction in 1962 ( only two unplarmed outages in the past 14 years, for a total
duration of only three minutes). Nonetheless, the Company states that it has taken a
number of steps to further improve the reliability of the line, including the following:
Tidwell First Production Request-IPC-E-16-28. 7
structural assessment, electrical assessment, fire protection, avalanche study, conductor
assessment, maintenance plan and emergency action plan.
Please provide the following, include work papers, back up documentation, memoranda and all
other material related to the preparation of each:
(A) a copy of the thorough review of the reliability of the Company's electric service to
the Ketchum/Sun Valley area referred to by the Commission in the above passage;
(B) a copy of the structural assessment;
(C) a copy of the electrical assessment;
D) a copy of the fire protection plan/assessment/review;
(E) a copy of the avalanche study;
(F) a copy of the conductor assessment;
(G) a copy of the maintenance plan; and
(H) a copy of the emergency action plan.
REQUEST FOR PRODUCTION NO. 19
The Company's Application states at page 11 that "Sun Valley stated that at the regular
City Council meeting of September 1, 2016, the council unanimously agreed that the redundant
line project was necessary and vital for its community ... " The Mayor of the City of Sun Valley
stated at the referenced meeting that, "It is not a vote, it is an expression of our wishes as far as
how they will tackle this project that they are mandated to do to provide us with power. They
[Idaho Power] have decided that they need to do this they are asking us to think about how we
want it done." Please reconcile the Application's assertion that the City of Sun Valley "agreed
that the redundant line project was necessary" with the Mayor's explanation that the need for the
line was already "decided" by Idaho Power and that the City Council was only asked to "think
Tidwell First Production Request-IPC-E-16-28. 8
about how we want it done."1
REQUEST FOR PRODUCTION NOS. 20 THROUGH 28
Request Nos. 20 through 28 reference the Company's 1995 Application ("1995
Application") to remove the authority granted to it in Certificate No. 272 to construct a second
138 kV line from Hailey to Ketchum.
REQUEST FOR PRODUCTION NO. 20
At page 4 of the 1995 Application the Company stated that:
Energy Data Management, Inc. of Colorado has performed a field inspection and
structural analysis of the poles, cross-arms, insulators, conductors and other components
of the transmission line. This study confirmed that the transmission line structures are in
good condition and are in conformance with applicable National Electrical Safety Code
standards. Structures and cross-arm identified in the study as needing work were
repaired.
Please provide a copy of the referenced study. Please also provide copies of all subsequent
similar studies. If there are no subsequent similar studies please explain why not. Please
provide maintenance and repair records for this line for the time period beginning in 1995.
REQUEST FOR PRODUCTION NO. 21
At page 5 of the 1995 Application the Company stated that:
Energy Data Management and Power Engineers of Hailey have analyzed the historical
performance of the transmission line, including outages and lightning-related incidents.
The transmission line was determined to have an excellent outage history, with only two
unplanned outages in the past fourteen years, for a total duration of only three minutes.
The electrical assessment was based upon Idaho Power's records and did not include any
brief outages which may not have been recorded for the line over the years.
Please provide a copy of the referenced electrical assessment. Please also provide copies of all
subsequent similar assessments. If there are no subsequent similar assessments please explain
1 City of Sun Valley audio transcript, September 1, 2016 at hour 1:45, emphasis provided. See:
http://sunvalley.granicus.com/MediaPlayer.php?view id=3&clip id=772
Tidwell First Production Request-IPC-E-16-28. 9
why not. Please provide a list of, including time, duration, cause, of all unplanned outages since
1995.
REQUEST FOR PRODUCTION NO. 21
At page 5 of the Company's 1995 Application the Company states:
Osmose, Inc. of New York has coated the transmission poles with Fire-Guard protectant,
which is designed to protect the poles through three fires.
Please provide an update on any subsequent fire protectant applications since 1995 and the
expected fire protection provided by said applications.
REQUEST FOR PRODUCTION NO. 22
At page 5 of the Company's 1995 Application the Company states:
Power Engineers and Energy Data Management have reviewed the probabilities and
severities of avalanches in the vicinity of the transmission line and calculated the
resulting pole strength requirements. All structures were determined to have adequate
strength to withstand a 50-year recurrence avalanche.
Please provide a copy of the referenced review. Please also provide any subsequent avalanche
reviews, ifthere are none please explain why not.
REQUEST FOR PRODUCTION NO. 23
At page 5 of the Company's 1995 Application the Company states, "Idaho Power has
developed an enhanced maintenance plan to repair and replace power line components as
needed." Please provide a copy of the "enhanced maintenance plan." Please also provide a
copy of any subsequent maintenance plan.
REQUEST FOR PRODUCTION NO. 24
At page 6 of the Company's 1995 Application the Company states:
Idaho Power has prepared a detailed, comprehensive emergency action plan to facilitate a
rapid and effective response to a service outage or other emergency regarding the power
line. The plan includes detailed maps and directions for access to structures, specific
guidelines for structure replacements, and contact lists for internal and external
Tidwell First Production Request-IPC-E-16-28. 10
communications ( e.g. law enforcement, hospitals, etc.) Materials are stored in Hailey to
facilitate the rapid restoration of service in the event of an unplanned line outage.
Please provide a copy of the "comprehensive emergency action plan" referenced above. Please
include all referenced detailed maps, directions, guidelines and contact lists. Please provide an
inventory of all "materials stored in Hailey to facilitate the rapid restoration of service" on the
line. Please also provide any subsequent updated or revised emergency action plans for
restoration of service on the line in the event of an unplanned outage.
REQUEST FOR PRODUCTION NO 25
At page 6 of the Company's 1995 Application, the Company states that it, "recently
completed an extensive public participation process regarding the possible construction of a
second 138 kV transmission line from the Wood River Substation to the Ketchum Substation" ..
. and, "at the conclusion ofldabo Power's public participation process, the Company carefully
evaluated the input received"
Please provide copies of the "input received" referenced above.
REQUEST FOR PRODUCTION NO. 26
At page 7 of the Company's 1995 Application, the Company states that:
Based on Idaho Power's extensive review of the proposal to construct a 13 8 kV
transmission line from the Wood River Substation to the Ketchum Substation, ... the
Company has conclude that the project is not feasible at this time.
Please provide a copy of the Company's "extensive review." Provide all supporting documents
and associated workpapers.
REQUEST FOR PRODUCTION NO. 27
At page 5 of the Company's 1995 Application, the Company stated that a one-mile
segment of the line was rerouted in 1994. Please explain the reason for the one-mile reroute.
Provide all work orders, and other documentation associated with the reroute, including a map
Tidwell First Production Request-IPC-E-16-28. 11
showing the old route and the new route. Please explain, and document, all outages associated
with the reroute construction. What was the total cost of the reroute, please provide supporting
documentation for your answer. How many structure replacements were required for the
reroute? Was the reroute completed without line outages, if so please detail how that was
accomplished, if not please detail the duration and reasons for the outages.
REQUEST FOR PRODUCTION NO. 28
Please provide all other documents, not provided in response to previous Requests, in
your possession related in any way to the Company's 1995 Application, these should include all
correspondence, production requests and responses, internal memoranda, studies, board minutes
and all other documentation.
REQUEST FOR PRODUCTION NO. 29
At page 18 of the Company's current Application, the Company states:
The North Valley exhibits several transmission siting obstacles for overhead access to the
existing Ketchum substation.
Please explain, document and detail how this statement is not also true for the Southern part of
the valley.
REQUEST FOR PRODUCTION NO 30
At page 18 of the Company's current Application the Company states that there are
several "transmission siting obstacles for overhead access to the Ketchum substation." One of
those obstacles is:
First, the North Valley is congested due to numerous residences and business sited in a
valley less than one mile wide with mountains of steep slope and narrow roadways.
Please explain, and document, how the route of the proposed new transmission line in the
portion other than the "North Valley" is not also congested due to numerous residences and
Tidwell First Production Request-IPC-E-16-28. 12
business sited in a valley less than one mile wide with mountains of steep slope and narrow
roadways.
REQUEST FOR PRODUCTION NO. 31
At page 18 of the Company's current Application the Company states that there are
several "transmission siting obstacles for overhead access to the Ketchum substation." One of
those obstacles is:
This would force an overhead transmission line ... spanning down over existing homes
near the substation.
Please explain, and document, how the route of the proposed new transmission line in the
southern portion near the Wood River substation does not also span over ( or span very near to or
adjacent to) existing homes near the substation.
REQUEST FOR PRODUCTION NO. 32
At page 18 of the Company's current Application the Company states that there are
several "transmission siting obstacles for overhead access to the Ketchum substation." One of
those obstacles is:
The cities of Ketchum and Sun Valley require new electrical facilities be located
underground.
Please explain, and document, how the route of the proposed new transmission line in the
southern portion of the Wood River Valley along scenic highway 75 is not also required to be
underground pursuant to the Blain County Comprehensive Plan.
REQUEST FOR PRODUCTION NO. 33
Please provide all studies, analysis or discussion and any other documentation in the
Company's possession addressing the impact of high-voltage power lines on property values in
Tidwell First Production Request-IPC-E-16-28. 13
general and specifically on residential property values. Please provide all such studies conducted
in conjunction with the proposed transmission line in this case.
REQUEST FOR PRODUCTION NO. 34
Has the Company conducted a cost benefit analysis comparing the total value of
diminished property values associated with the proposed overhead transmission line to the
incremental costs ofundergrounding the line? If so please provide a copy of the study(ies) along
with supporting workpapers and documentation. If not, please explain why not.
REQUEST FOR PRODUCTION NO. 35
Has the Company conducted a study of the magnitude of lost revenues to the taxing
districts along the proposed route due to diminished property values associated with the
construction of the proposed overhead transmission line. If so, please provide a copy of the
study(ies) along with supporting workpapers and documentation. If not, please explain why not.
DATED this 10th dayofFebruary2017.
Tidwell First Production Request-IPC-E-16-28. 14
Richardson Adams, PLLC
By u2Al ~___,
Peter J. Richardson Attorney for
Kiki Leslie A. Tidwell
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of February, 2017, a true and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL
TO IDAHO POWER COMPANY, in Docket No. IPC-E-16-28 was served VIA ELECTRONIC
MAIL ONLY to the following:
Commission Secretary
Idaho Public Utilities Commission
POBox83720
Boise ID 83720-0074
[e-mail]
Tim Tatum
Idaho Power Company
1221 West Idaho Street
P.O. Box 70
Boise, Idaho 83 707
[e-mail]
Zack Waterman
Idaho Sierra Club
503 W. Franklin Street
Boise, Idaho 83 702
Zack. [e-mail]
Laura Midgley
231 Valley Club Drive
Hailey, Idaho 83333
[e-mail]
C. Tom Arkoosh
Arkoosh Law Offices
802 West Bannock Street
Boise, Idaho 83 702
[e-mail]
[e-mail]
Tidwell First Production Request -IPC-E-16-28.
Donovan E. Walker
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83 702
[e-mail]
[e-mail]
Daphne Huang
Camille Christen
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83 702
[e-mail]
[e-mail]
Benjamin Otto
Idaho Conservation League
710 N. Sixth Street
Boise, Idaho 83 702
[e-mail]
Matthew A. Johnson
WmF. Gigray
White Peterson Gigray & Nichols, PA
5700 E. Franklin Rd., Ste. 200
Nampa, Idaho 83687
[e-mail]
()=>~,~~
Peter J. RictZ,son
15