20170303IPC to Tidwell 1-35.pdf

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DONOVAN E. WALKER
Lead Counsel
dwal [e-mail]
March 3,2017
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
ldaho Power Company's Response to the First Production Request of Kiki
Leslie A. Tidwell
Dear Ms. Hanian:
Enclosed for filing in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the First Production Request of Kiki Leslie A.
Tidwell.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to Ms. Tidwell's production requests.
very yours,
Donovan E. Walker
DEW:csb
Enclosures
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
An IDACORP Company
...."i,iIrr,],;lni,lr-11\ i\i*ivlt
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower.com
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Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
CERTIFICATE OF PUBLIC CONVE}ffENCE
AND NECESSIW FOR THE WOOD RIVER
VALLEY
CASE NO. !PC-E-16-28
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
KIKI LESLIE A. TIDWELL
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Comp?ry"), and in
response to the First Production Request of Kiki Leslie A. Tidwell to ldaho Power
Company dated February 10,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 1
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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 forma! or informal.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: To date, ldaho Power
has received production requests from the ldaho Public Utilities Commission
("Commission") Staff ("Staff') and Kiki Leslie A. Tidwell. Copies of ldaho Power
Company's Response to Staffs First Production Request were served on the parties on
February 17, 2017. Copies of ldaho Power's responses to discovery requests in this
case will be provided to all intervening parties.
The response to this Request is sponsored by Christa Bearry, Legal Assistant,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 2
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 ldaho 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. lnclude 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 electrica!
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 forecast.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2:
A) A map of the existing transmission line is provided as Attachment 1 and a
map of the distribution facilities is provided as Attachment 2 on the enclosed CD.
B) The term "sustained outage line events" can be defined as an interruption
in service lasting more than five minutes due to line conductor, insulator, or structure
failures. These have multiple causes, including vandalism, inclement weather, wood
decay, woodpecker damage, avalanche, fire, or micro-burst wind events:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 3
C) When an outage occurs, a restoration crew will identify the cause and
restore service. ldaho Power does not typically track the costs of individual line events.
The following table provides the rest of the requested outage information.
Date
Duration
(minutes)Cause
sl3LlLses lo4 Maintenance
81141t998 5 Unknown
LlL(2004 10 Weather
LOILLI2OO4 108 Maintenance - Repair Vandalism Damage
2lL8l2OOs 58 Equipment Failure
L2/2412009 700 Weather
9/27l20tt 342 Maintenance
6/4120L4 46 Equipment Failure - Broken Cross Arms
th212074 L26 Lightning
L0lt3/2OLs 465 Maintenance - Repair Woodpecker Damage
D) There is one distribution circuit tie switch to an adjacent circuit, HALY-1S
fed from the Hailey substation, available to the North Valley (please see Attachment 2).
E) The "forecast to increase in frequency" is based upon the fact that the line
was built in 1962 and its components are aging. When looking to the future, the
Company applies industry knowledge that equipment failure rates increase with age.
Please see the Direct Testimony of David M. Angell, pp.20-21.
O. Has ldaho Power estimated the potential for
future sustained outages in the North Valley?
A. Yes. Historically, this particular line has had a
relatively good service record for reliability. This was one of
the reasons that the previously issued CPCN was withdrawn
in 1995. However, this line, built in 1962, has not aged well
and now requires complete reconstruction. ldaho Power
estimates that without any significant changes to the existing
North Valley transmission line, the expectation could be that
the current configuration will result in an average duration of
sustained outages of more than 209 minutes per year.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 4
The 209 minutes of sustained outage per year was estimated for outages caused
by a loss of 138 kilovolt ('kV') transmission north of the Wood River substation, using
ldaho Power system average data for 138 kV transmission lines and historical Wood
River-Ketchum 138 kV line performance, which is better than the ldaho Power system
average for 138 kV transmission lines.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 5
REQUEST FOR PRODUCTION NO. 3: The Com pany'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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The quoted language
above could not be located on page 3 of the Application; however, it appears to come
from the second paragraph of page 2 of the Application. This is the beginning of the
Application's request and states:
The Company requests, pursuant to ldaho Code SS 61-508
and 61-526, that the Commission find it to be in the public
convenience and necessity that ldaho Power construct a
new 138 kV transmission line as a redundant source of
energy into the Wood River Valley north of East Fork
Road. . . . Additionally, the existing radial transmission line,
constructed in 1962, is aged and must be reconstructed.
The proposed facilities follow the same path and will replace
existing distribution lines, which minimizes the aesthetic
impact.
The first sentence in this Request for Production quotation is discussing the
existing line. The second sentence in the quotation is discussing the proposed
redundant line. The statement, "proposed facilities will follow the same path" refers to
the construction of a new 138 kV transmission line as a redundant source following the
same path as the "existing distribution lines." This route is depicted on the map which
accompanies the Direct Testimony of David M. Angel! as Exhibit No. 4.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL.6
REQUEST FOR PRODUCTION NO. 4: Footnote 1, on page 3 of the Application
states that ldaho 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: ldaho Power objects to
this Request for Production as it is overly broad, burdensome, and requests materials
that are attorney-client privileged communication and attorney-work product. Some
materials, such as pleadings are publicly available from the Commission.
Notwithstanding and without waiving said objection, in addition to what is provided in
response to the other requests for production contained in the First Production Request
of Kiki Leslie A. Tidwell ("Tidwell") to Idaho Power, and excluding attorney-client
privileged and attorney-work product, please see Attachment 1 provided on the
enclosed CD. Excluded from Attachment 1 are severa! maps that appear to be related
mainly to the proposed generation facility that was the main topic of Case No. U-1006-
89. Because of their large size, these maps wil! be made available for inspection at
ldaho Power. Please contact Donovan E. Walker if you wish to arrange a time to review
the maps.
The response to this Request is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 7
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. lC-E-95-6 fsrd that, "Because the project, the Company
concludes, is neither needed nor feasible, the Company requests authority to amend [its
CPCNI by removing the language authorizing the construction by ldaho 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Reconciliation of the
two above-referenced statements is explained in ldaho Power's initial pleadings in this
matter, Case No. IPC-E-16-28: the Application; Direct Testimonies of David M. Angell,
Ryan N. Adelman, and Michael J. Youngblood; the accompanying exhibits submitted
therewith; as well as the passage of more than 20 years since the IPC-E-95-06 matter.
ldaho Power objects to this Request for Production as it is overly broad,
burdensome, and requests materials that are attorney-client privileged communication
and attorney-work product. Some materials, such as pleadings are publicly available
from the Commission. Notwithstanding and without waiving said objection, ldaho Power
has provided materials related to Case No. !PC-E-95-06 in response to the other
requests for production contained in the First Production Request of Kiki Leslie A.
Tidwell to ldaho Power, excluding attorney-client privileged and attorney-work product
information. There are no Board of Director materials from the 1973 or 1995 cases.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 8
Please see ldaho Power's responses to Request for Production Nos. 6, 16, 18,20,21,
21[sic], 22,23, 24, 25,26, 27 , and 28 for materials or documentation.
The response to this Request is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 9
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 !PC-E-95-6.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Idaho Power objects to
this Request for Production as it is overly broad, burdensome, and requests materials
that are attorney-client privileged communication and attorney-work product. Some
materials, such as pleadings are publicly available from the Commission.
Notwithstanding and without waiving said objection, ldaho Power has provided
materials related to Case No. IPC-E-95-06 in response to the other requests for
production contained in the First Production Request of Kiki Leslie A. Tidwell to ldaho
Power, excluding attorney-client privileged and attorney-work product information.
There are no Board of Director materials from the 1973 or 1995 cases. Please see
ldaho Power's responses to Request for Production Nos. 6, 16, 18,20,21,21[sic], 22,
23,24,25,26, 27 , and 28 for materials or documentation.
The response to this Request is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A, TIDWELL - 1O
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, identifo 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The peak coincident
demand for the North Valley is the sum of the Elkhorn and Ketchum substation
transformer coincident demands as acquired by the substations supervisory control and
data acquisition (SCADA) system, which are stored in a OSlsoft Process lnformation
("P1") data historian. The Pl historian maintains data back to 2000. Please refer to
Table 7.1 below for the date and time of the coincident North Valley peak demand and
Table 7 .2 below for the peak demand of each substation.
Table 7.1
Coincident Peak of North Valley
Year North Valley Peak (MW)EKHN (MWI KCHM (MW)Date and Time
Winter 00-01 52.5 9.1 43.4 1l'161018:30 AM
Winter 0'l-02 51.2 8.7 42.5 121121018:25 AM
Winter 02-03 54.9 9.6 45.3 12124102 9:05 AM
Winter 03-04 54.9 9.4 45.5 12128103 5:45 PM
Winter 04-05 56.3 11.2 45.1 12123104 9:20 AM
Winter 05-06 55.9 12.2 43.7 1218105 8:50 AM
Winter 06-07 60.6 12.8 47.8 1113107 9:20 AM
Winter 07-08 63.8 14.3 49.5 12131107 6:45 PM
Winter 08-09 59.2 12.9 46.3 1212410810:00 AM
Winter 09-10 57.9 1't.9 46.0 '1213110910:30 AM
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 11
Winter 10-11 62.0 12.9 49.1 1213111O 9:50 AM
Table 7.2
Non-Coincident Peaks For Ketchum and Elkhorn Substations
Year KCHM Peak (MW)Date and Time EKHN Peak (MW)Date and Time
Winter 00-0'1 43.5 11161018:35 AM 9.7 12128100 6:15 PM
Winter 01-02 42.5 121121018:30 AM 9.9 1212910'17:00 PM
Winter 02-03 45.4 12124102 9:00 AM 9.6 12124102 9:00 AM
Winter 03-04 46.1 1212810310:15 AM 9.8 12128103 6:55 PM
Winter 04-05 45.1 12123104 9:25 AM 12.0 12123104 7:00 PM
Winter 05-06 46.1 12118105 9:25 AM '12.2 1218105 8:55 AM
Winter 06-07 47.8 1113107 9:20 AM 13.3 1115107 9:00 AM
Winter 07-08 50.4 12127107 9:35 AM 14.3 12131107 6:55 PM
Winter 08-09 46.3 12124108 9:40 AM 13.3 12127108 6:55 PM
Winter 09-10 46.0 1213110910:30 AM 14.2 12125109 5:00 PM
Winter 10-11 49.2 1213111O 10:05 AM 14.3 12131110 6:55 PM
Winter 11-12 44.6 12123111 9:25 AM 12.3 '12131111 6:30 PM
Winter 12-13 46.2 1l'14113 8:55 AM 13.5 12131112 6:15 PM
Winter 13-'14 42.7 12129113 9:20 AM 11.7 12129113 6:30 PM
Winter 14-15 46.9 12131114 9:45 AM 13.7 12131114 6:20 PM
Winter 15-16 46.8 12131115 6:05 PM 14.3 12131115 6:25 PM
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 12
Winter 11-12 55.5 10.8 44.6 12123111 9:25 AM
Winter 12-13 59.5 13.3 46.2 1114113 8:55 AM
Winter 13-14 54.0 11.3 42.7 12129113 9:30 AM
Winter 14-15 59.7 13.7 46.0 12131114 6:20 PM
Winter 15-16 60.8 't4.1 46.7 12131115 6:10 PM
REQUEST FOR 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Three main factors
contribute to the variability of peak load in the North Valley: temperature, snow fall, and
tourism-based lodging occupancy. Electrical demand increases with decreased
temperatures, increased snow making when concurrent with chair Iift operations, and
higher lodging occupancy.
Even with the variability described above, the average of the 2011 to 2A15 winter
peaks is 2.8 megawatts ("MW') higher than the average of the peaks from 2001 to
2005.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF KIKI LESLIE A. TIDWELL - 13
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: As discussed in the
Company's response to Tidwell's Request for Production No. 8, the peak load is
dependent on the temperature, mountain ski operations, and lodging occupancy. The
peak load variations shown in the Coincident Peak table provided in the Company's
response to Tidwell's Request for Production No. 7 does not reflect a declining load but
the coincidence or lack of coincidence between the three dependencies described.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKl LESLIE A. TIDWELL - 14
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.'
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Please refer to the
Coincident Peak table provided in the Company's response to Tidwell's Request for
Production No. 7; the average of the winter peaks from the 200O12007 through
201512016 is about 60 MW.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A, TIDWELL - 15
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? lf 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: The distribution circuit
along State Highway 75, HALY-1S sourced from the Hailey substation, has one
distribution tie to the North Valley (please see the map provided on the enclosed CD). lf
the transmission line to the North Valley was out of service at winter peak demand, 1.3
MW could be restored on the alternate source. Distribution switches would be manually
operated in order to restore the load.
The response to this Request is sponsored by David Angel!, Customer
Operations Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 16
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Please see the maps
provided on the enclosed CD. The access locations with residential impediments (a)
are shown in Attachments 1 and 2. Rough terrain areas (b) are shown in Attachment 3.
Attachment 4 identifies with dashed lines all aged construction roads (c).
The language in private property easements grants to ldaho Power "all rights of
ingress and egress necessary for the full and complete use, occupation and enjoyment
of the easement hereby granted."
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 17
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 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
(0 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: The following table
(Attachment 1) lists for a through g all recorded outages on the Wood River-Ketchum
138 kV Line 433 from 1995 to present.
off
Duration_
Minutes
7
On
3:02:00 PM 4:46:00 PM
5:53:00 PM 5:53:OO PM
5:40:00 PM 7 6:44:00 PM
3:O8:OO PM 8/74/1998 3:13:00 PM
5:44:00 PM 5:54:00 PM
12:04:00 AM 1:52:00 AM
Cause
104 Sustained Maintenance
0 Momenta Weather
4 Momenta Weather
5 Momenta Unknown
Sustained
Sustained Vandalism
6:58:O0 PM 7:56:00 PM 58 Sustained
1 12:04:00 AM 5:53:00 AM
4:28:00 PM 7 4:28:00 PM
5:35:00 PM 7:4L:OOPM
11:OO:OO PM 6:45:OO AM
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL. 18
349 Sustained Maintenance
Failure
Failure70 Momenta
126 Sustained Weather
4S5Sustained Maintenance
Comments
27340452 Str. & Xarm Repair
27 439I9t Woodpecker Repa ir
Provided as Attachments 2 and 3 on the enclosed CD are the summaries of
costs for the two identified work orders, 27340452 and 27439191, respectively.
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 19
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: The areas marked on
the map provided on the enclosed CD are areas identified by ldaho Power as having
steep terrain and/or areas where snow accumulations are not routinely plowed and
therefore have restricted winter access to the WDRI-KCHM Line 433.
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF KIKI LESLIE A. TIDWELL - 20
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Please see
Attachment 1 provided on the enclosed CD, which is a map identifying land ownership
of the existing line as to Bureau of Land Management ("BLM"), state of Idaho, and
private ownership. Please see Attachment 2 provided on the enclosed CD for copies of
the easements related to the private ownership portions of the existing line route. The
easements are also identified on the map included as Aftachment 1.
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 KIKI LESLIE A. TIDWELL - 21
REQUEST FOR PRODUCTION NO. 16: The Com pany's application provides at
page 7, that "At the Company's request, the 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Please see the
Company's response to Tidwell's Request for Production No. 6.
The response to this Request is sponsored Donovan E. Walker, Lead Counsel,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 22
REQUEST FOR PRODUCTION NO. 17: On page 7 of the Company's
Application is a list of reasons 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 of
local funding of incremental cost of placing part or al! 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: The proposed route
follows existing transportation corridors between Hailey and Ketchum. There were
general routes discussed with the public, BLM, and Forest Service in the early 1990s.
However, detailed routes were not established at that time, and there were no analyses
performed on aesthetics, health and safety concerns, or localfunding.
Notwithstanding the above response, the quoted language in this Request for
Production is taken from both the Applications Filed in Case Nos. IPC-E-95-06 and
IPC-E-16-28. !t is an expression of the reasons for public opposition from 1995, and
ldaho Power's belief is that these are the same and/or similar reasons for public
opposition to the proposed line today.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL.23
REQUEST FOR PRODUCTION NO. 18: ln 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
1and2
Regarding reliability, ldaho 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 unplanned 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: 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)
(c)
D)
(E)
(F)
(G)
(H)
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 24
a copy of the structural assessment;
a copy of the electrical assessment;
a copy of the fire protection plan/assessmenUreview;
a copy of the avalanche study;
a copy of the conductor assessment'
a copy of the maintenance plan; and
a copy of the emergency action plan.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
(A) No single document encompasses a "thorough review" as described.
Attachments 1-8 provided on the enclosed CD, when taken together, would comprise a
"thorough review."
(B) Please see the structural assessment and appendices provided as
Attachments 1 and 3 on the enclosed CD.
(C) Please see the electrical assessment provided as Attachment 2 on the
enclosed CD.
(D) A fire assessment was never done. lnstead, ldaho Power chose to treat
all the wood poles on the existing WDRI-KCHM Line 433 with a spray-on product called
Fire-Guard from Osmose to protect the poles from wild land fires.
(E) Please see the avalanche study and avalanche maps attached as
Attachments 4 and 5 on the enclosed CD.
(F) A conductor assessment study has not been prepared.
(G) The "maintenance plan" as referenced in this Request for Production no
longer exists. A verbal historical account of the plan indicates that it reflects the current
maintenance plan as described in the Transmission Maintenance and Inspection Plan
(TMIP) provided as Attachment 6 on the enclosed CD.
(H) Please see the emergency action plans provided as Attachments 7 and 8
on the enclosed CD.
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 25
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, "lt 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. Thev
lldaho Powerl have decided that thev need to do this they are askino 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 ldaho Power and that
the City Council was only asked to "think about how we want it done."1
RESPONSE TO REQUEST FOR PRODUCTION NO. {9:The Company's
statement on page 11 of its Application refers to a letter received from the City of Sun
Valley, dated September 29,2016, which was sent to the Company as well as filed with
the Commission. The letter is an expression of the City's official action, and the words
and contents of the letter speak for themselves.
The letter, signed by Peter M. Hendricks, Mayor of the City of Sun Valley, states
"the City has been thoroughly informed on the purpose and need, as well as the impacts
of potential routing options." The letter continues to state that:
At the regular City Council meeting of September 1't, the
Council unanimously agreed on the following project scope
and components:
I City of Sun Valley audio transcript, September 1, 2016 at hour 1:45, emphasis provided. See:
http://su nvalley. granicus.com/MediaPlayer. php?view id=3&clip id=772
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL.26
1)That the redundant line project is necessary and
vital for our community, which is geographically
isolated, has substantial wildfire risk, relies heavily on
tourism during the winter, and experiences severe
winter weather.
The letter continues
2)That the best location at which to underground
the line is near the intersections of Highway 75
and Elkhorn Road, because it offers the best
combination of low project cost and low visual impacts
to the combined communities of Ketchum and Sun
Valley.
(Emphasis in original.)
The Mayor also stated that the "City of Sun Valley understands that this line will
provide the opportunity to eventually replace the aging and dilapidated Wood River-to-
Elkhorn line, which is also important to maintaining the reliability of electrica! power in
our community."
The response to this Request is sponsored by Michael J. Youngblood, Manager
of Regulatory Projects, ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 27
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, lnc. 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. lf 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Please see the
Energy Data Management, lnc. of Colorado ("EDM") Structural Reliability and Risk
Assessment Final Report, Electrical Report, and Appendices, provided as
Attachments 1 , 2, and 3 on the enclosed CD. No subsequent studies have been
prepared since the study prepared by EDM in 1993. No subsequent reports were
commissioned. The major change over time subsequent to the study is the physical
condition of the line. The line is an active part of the ldaho Power provision of service to
its customers and is patrolled twice a year by an ldaho Power patrolman to detect and
report changes in condition.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 28
Please see Attachments 1-7 provided on the enclosed CD, which provide the
maintenance and repair records for the WDRI-KCHM line. ldaho Power maintenance
for this section of transmission line includes inspection maintenance and general
maintenance. lnspection maintenance is a result of ldaho Power inspections that are
performed by Idaho Power transmission patrolmen or qualified contractors in
accordance with the inspection plan as outlined in the Transmission Maintenance
Inspection Plan (TMIP) (please see Attachment 6 provided in the Company's response
to Tidwell's Request for Production No. 18). General maintenance is due to local
incidences and includes small minor repairs, such as new bolts, washers, etc. A record
of the date material was issued and the material requested is provided as the repair
record (Attachment 1).
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Gompany, and Jill Glenn, Transmission and Distribution
Process Leader, ldaho Power Company.
]DAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 29
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 historica! 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 ldaho 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 electrica! assessment. Please also provide
copies of all subsequent similar assessments. lf there are no subsequent similar
assessments please explain why not. Please provide a list of, including time, duration,
cause, of all unplanned outages since 1995.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2{: Please see EDM's
Structural Reliability and Risk Assessment - Addendum to Final Report, Electrica!
Reliability Study provided as Attachment 2 to the Company's response to Tidwell's
Request for Production No. 18. There are no subsequent studies that have been
prepared since the one prepared by EDM in 1993. No subsequent reports were
commissioned. The major change over time subsequent to the study is the physical
condition of the line. The line is an active part of ldaho Power's provision of service to
its customers and is patrolled twice a year by an ldaho Power patrolman to detect and
report changes in condition.
Please see the spreadsheet provided on the enclosed CD for all of the recorded
outages on the Wood River-Ketchum 138 kV Line 433 from 1995 to present.
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 30
REQUEST FOR PRODUGTION NO.21 Isrcl: At page 5 of the Company's 1995
Application the Company states:
Osmose, lnc. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21 Isicl: Please see the
PDF provided on the enclosed CD for product information on Osmose Fire-Guard
coating. All the poles on the Wood River-Ketchum 138 kV line were treated with this
product in 1994. The coating is advertised to protect the wood poles from fire for two-
three burn cycles. None of the poles on this line have been exposed to fire since the
coating was applied in 1994. There has been no subsequent treatment of the poles
since 1994.
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 31
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 S0-year recurrence
avalanche.
Please provide a copy of the referenced review. Please also provide any subsequent
avalanche reviews, if there are none please explain why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: Please see the Power
Engineers' Structural Reliability, Risk Assessment & Avalanche Line Loadings report
included as Attachment 4 to the Company's response to Tidwell's Request for
Production No. 18. There are no subsequent studies that have been prepared since the
one prepared by Power Engineers in 1994. No subsequent reports have been
commissioned.
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 32
REQUEST FOR PRODUCTION NO. 23: At page 5 of the Company's 1995
Application the Company states, "ldaho 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: A physical copy of the
"enhanced maintenance plan" as referenced at page 5 of the Company's 1995
Application no longer exists. A verbal historical account of the plan indicates that it
reflects the current maintenance plan as described in the document titled "Transmission
Maintenance and Inspection Plan (TMIP)" provided as Attachment 6 to the Company's
response to Tidwell's Request for Production No. 18.
The response to this Request is sponsored by Jil! Glenn, Transmission and
Distribution Process Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 33
REQUEST FOR PRODUCTION NO. 24:At page 6 of the Company's 1995
Application the Company states:
ldaho 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 communications (e.9. law enforcement, hospitals,
etc.) Materials are stored in Hailey to facilitate the rapid
restoration of service in the event of an unplanned line
outage.
PIease 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24: Please see the ldaho
Power Wood River-Ketchum 138 kV Emergency Action Plan from 1995 provided as
Attachment 7 to the Company's response to Tidwell's Request for Production No. 18.
Also provided as Attachment 8 to the Company's response to Tidwell's Request for
Production No. 18 is ldaho Power's current Wood River-Ketchum 138 kV Emergency
Action Plan from 2016. Materials stored in Hailey, for emergency restoration efforts, are
shown in the Emergency Action Plan under the heading "Structure list and
Miscellaneous."
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 34
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 of ldaho Power's public participation process, the Company carefully
evaluated the input received"
Please provide copies of the "input received" referenced above.
RESPONSE TO REQUEST FOR PRODUCTION NO. 25: Please see the PDF
provided on the enclosed CD containing the following information related to the process:
1. lntroduction (description of public participation process)
2. Comments from Open House, January 25, 1995
3. Wood River to Ketchum Community Advisory Committee Members
4. Newspaper articles:
o Times News (02115195),
. Wood River Journa! (211195),
o Times News (02115195)
The response to this Request is sponsored by Dan Olmstead, Community
Relations Representative, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL.35
REQUEST FOR PRODUCTION NO. 26: At page 7 of the Company's 1995
Application, the Company states that:
Based on ldaho Power's extensive review of the proposal to
construct a 138 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26: Following are the
areas and general conclusions covered in the " extensive review":
1. Structural Assessment. Energy Data Management, lnc., of Colorado
provided as Attachment 1 to the Company's response to Tidwell's Request for
Production No. 18.
2. Electrical Assessment. Data Management and Power Engineers of
Hailey, ldaho, provided as Attachment 2 to the Company's response to Tidwell's
Request for Production No. 18.
3. Fire Protection. Osmose , lnc., of New York, provided as an attachment to
the Company's response to Tidwell's Request for Production No. 21 [sic].
4. Avalanche Studv. Power Engineers and Energy Data Management,
provided as Attachment 4 to the Company's response to Tidwell's Request for
Production No. 18.
5. Conductor Assessment. ldaho Power.
6. Maintenance Plan. ldaho Power, provided as Attachment 6 to the
Company's response to Tidwell's Request for Production No. 18.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 36
7. Emeroencv Action Plan. ldaho Power, provided as Attachments 7 and 8
to the Company's response to Tidwell's Request for Production No. 18.
The response to this Request is sponsored by Dan Olmstead, Customer
Relations Representative, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL.3T
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 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27: The reroute was at a
customer's request, the Valley Club golf course developer. Please see Aftachment 1
provided on the enclosed CD for a copy of the construction documents. Also, provided
as Attachments 2 and 3 on the enclosed CD, please see a map showing the old route
and the new route. The two, short outages associated with this relocation project are
listed on page 1 and 2 of the technical specifications section of the construction
documents. The Company does not have documents that give the date or time of these
outages, but the outages were scheduled to be taken between 5:00 a.m. and 7:00 a.m.
A copy of the work order costs is shown in Attachment 4 provided on the enclosed CD.
On the reroute for Valley Club, eleven H-frame structures were removed and 22
structures were installed (21 of which were single-pole structures). There were two,
short outages associated with this relocation project. The constraints of the outages are
listed on page 1 and 2 of the technical specifications section of the construction
documents. The reason for the outages was to de-energize the existing line section so
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 38
that it could be removed and to energize the new section of line. All costs associated
with the project were funded by Valley Ranch Golf Course.
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 39
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 28: Please see the
Company's response to Tidwell's Request for Production No. 6.
The response to this Request is sponsored by Donovan E. Walker, Lead
Counsel, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 40
REQUEST FOR PRODUCTION NO. 29: At page 18 of the Company's current
Application, the Company states:
The North Valley exhibits severa! 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 29: While the entirety of
the Company's service territory in the Wood River Valley could generally be described
as having some similar attributes or obstacles to the siting of transmission lines and
facilities, the "North Valley" is defined in the Application as, "the Wood River Valley
north of East Fork Road, including the communities of Sun Valley, Ketchum, and areas
of Blaine County ('North Valley')." lt is unclear what is meant in this Request for
Production when referring to "the Southern part of the valley."
The above-quoted language from page 18 of the Company's Application is the
first sentence of paragraph 32 of the Application. This is the beginning of the
Application's summary of the overhead transmission routing options and states:
The North Valley exhibits several transmission siting
obstacles for overhead access to the existing Ketchum
substation. First, the North Valley is congested due to
numerous residences and businesses sited in a valley less
than one mile wide with mountains of steep slope and
narrow roadways. This would force an overhead
transmission line either through the downtown district of
Ketchum or over the top of Dollar Mountain and spanning
down over existing homes near the substation. Second, thevalley has multiple ordinances restricting certain
development. For example, because of these steep slopes
and for aesthetic reasons, Blaine County has an ordinance
limiting the development along the mountains (Mountain
Overlay District). ln addition, the cities of Ketchum and Sun
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 41
Valley require new electrical facilities be located
underground. Third, the community is adamantly against
additional visual impacts. ldaho Power representatives have
been advised that new overhead lines would not be allowed
in Ketchum and Sun Valley. Mr. Angell's Exhibit No. 4
contains a map depicting each Overhead Transmission
route: Dollar Mountain and Downtown District.
The southern portion of the Wood River Valley does not have the same
conditions as attempting to place an overhead transmission line through downtown
Ketchum or across Dollar Mountain and into the Ketchum substation. The jurisdictions
in the southern portion of the Wood River Valley do not have similar ordinances and
requirements for undergrounding of facilities.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 42
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 business sited in a valley less than one mile wide with mountains of
steep slope and narrow roadways.
RESPONSE TO REQUEST FOR PRODUCTION NO. 30: The northern portion
of the Wood River Valley narrows down to about one-third of a mile and the road right-
of-way that the proposed line would follow is substantially narrower in the northern part
of the project. This reduces the separation between the proposed power line and
homes/businesses along the route.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 43
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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 31: The proposed new
transmission Iine in the southern portion near the Wood River substation would run
adjacent to homes, but would not be physically spanning over the top of homes, which
is currently the case where the existing line comes off of Dollar Mountain near the
Ketchum substation.
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 KIKI LESLIE A. TIDWELL - 44
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 [src/ County Comprehensive
Plan.
RESPONSE TO REQUEST FOR PRODUCTION NO. 32: The Blaine County
Comprehensive Plan ("Plan") favors the use of underground power lines within scenic
corridors, such as the Highway 75 corridor, where ldaho Power's proposed 138 kV
transmission line ("Transmission Line") would be located. However, the PIan does not
require the underground location of power lines within scenic corridors, and lists several
other relevant considerations for undergrounding power lines, such as cost. Below are
excerpts from the Plan on the subject of underground power lines (emphasis added).
Note that the Plan's support for undergrounding power lines within scenic corridors is
qualified by the phrases "wherever possible" and "whenever possible."
8-1-1-7: SECTION 6. HISTORICAL BACKGROUND,
SOCIAL ENVIRONMENT, AND AESTHETIC VALUES
Utilitv lines are also a neqative visual intrusion. Blaine
County shall adopt a policy of requirino the underoroundino
of all utilitv lines wherever possible. !n the Scenic Corridors.
this shall be of the hiohest prioritv.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 45
The location and alignment of roadways can preserve or
enhance specific scenic qualities, which should be
considered in future alignment planning. Location of
necessary. but often unsiohtlv. public utilities should be
placed out of the view corridors whenever possible. Cost
alone shalllot be the decidinq factor for such relocation.
8-1-1-9: SEGTION 8. IMPLEMENTATION
Funding can come from the general fund, or it can come
from one of a number of other sources: general obligation
bonds; revenue bonds (in those cases where the
improvement will generate revenue); service charges
(commonly used to help finance utility systems); special tax
levies; special assessments; impact and mitigation fees; and
assistance in the form of grants from the State or Federal
government.
8-1-1-14: SECTION 13. PUBLIC SERVICES, FACILITIES,
AND UTILITIES:
SECTION 13: PUBLIC SERVICES, FACILITIES, AND
UTILITIES
INTRODUCTION
This section is a guide for decision making for public
services, facilities and utilities in Blaine County. Predictions
of continued population growth make planning for future
utilities and public service facilities essential. Blaine County
is a resort community and the north portion of the county
experiences seasonal fluctuations in population as high as
three times its permanent population. Utilities and public
facilities must have the ability to accommodate such
fluctuations. Blaine County will have a greater opportunity to
effectively serve the future needs of its permanent and visitor
population with careful planning.
PURPOSE
The purpose of the Public Services, Facilities, and Utilities
section is to identify the county's facilities and utilities, as set
forth in ldaho Code 67-6508 (f), and provide an inventory of
previous and existing conditions, discuss areas of service
and methods of operation, estimate projected future needs,
and provide recommendations for desirable goals and
objectives based on this information.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 46
UTILITIES
Public Utilities include basic services which provide for the
energy, communication, water delivery and public waste
removal needs of the county. These facilities include public
and investor owned and/or private utilities. Public utilities are
regulated by state and federal commissions.
Electric Power
With the exception of the Stanley Basin, Blaine County is
served by Idaho Power Company, ldaho's largest investor-
owned electric utility. The Stanley Basin is served by the
Salmon River Power Cooperative.
ldaho Power Company (ldaho Power) operates under a
Certificate of Public Convenience and Necessity granted by
the ldaho Public Utilities Commission,and is subiect to the
General Rules. Reoulations. and Rates approved bv the
Commission.
ldaho Power serves Blaine County with two (2) 138,000-volt
transmission lines. Both transmission lines terminate at the
Wood River Substation, two (2) miles north of Hailey. One
138.000-volt transmission line from Wood River to Ketchum
serves the northern areas of the county.
At year end 1990, Idaho Power served twelve thousand
thirty (12,030) customers in Blaine County from five (5)
distribution substations. Power line miles include:
1. Transmission - 144.5 miles.
2. Distribution Overhead - Three hundred nineg-six
(396) miles.
3. Distribution Underground - One hundred eighty-two
(182) miles.
During 1989 and 1990, ldaho Power in Blaine County,
experienced the fastest percentage growth in its service
territory. Five hundred thirty-eight (538) or four and one-half
percent (4.5o/o') new customers were added in 1989, and six
hundred four (604) or five percent (5%) new customers were
added in 1990.
The ldaho Power Company Regional Economic Forecast for
Blaine County, as filed with the ldaho Public Utilities
Commission in March of 1991, forecasts an annual
]DAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 47
population increase between 1991 and 2006 of four and
bnb-naf percent (41h%). Population totals are as follows:
Estimated Blaine
Year Gountv Population
1991 14,400
2006 24,500
ln order to provide reliable service and meet projected
population and load growth, ldaho Power planning includes:
1. A second 138,000-volt transmission line from the
Wood River substation (iust north of Hailev) to Ketchum.
2. Possibly two (2) new distribution substations.
3. New distribution feeder lines serving the groMh
areas.
ldaho Power planninq process issues include, but are not
limited to. the followi nq
1. Corridor versus private easements and alternative
routinq.
2. Overhead versus underqround.
3. Electric and maqnetic fields
4. Enqineerinq desiqn of new and uporaded
transmission and distribution facilities should include:
a. Cost.
b. Blaine Countv Comprehensive Plan.
c. Local economic issues.
The response to this Request is sponsored by Pat Harrington, Corporate
Secretary, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 48
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 general and specifically on
residentia! property values. Please provide al! such studies conducted in conjunction
with the proposed transmission line in this case.
RESPONSE TO REQUEST FOR PRODUCTION NO. 33: ldaho Power has
conducted no studies, analyses, or had discussions regarding the impact of high-
voltage power lines on property values in general and specifically on residential property
values.
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 KIKI LESLIE A. TIDWELL - 49
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 of undergrounding the
line? lf so please provide a copy of the study(ies) along with supporting workpapers
and documentation. lf not, please explain why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 34: No, Idaho Power has
not conducted a cost-benefit analysis comparing the total value of diminished property
values associated with the proposed overhead transmission line to the incremental
costs of undergrounding the line. ldaho Power notes that nearly al! of the proposed
overhead transmission line will be located on public right-of-way, not private property.
ln addition, most of the proposed overhead transmission line will replace distribution
lines already in place along the proposed overhead transmission line route.
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 KIKI LESLIE A. TIDWELL - 50
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. !f so, please provide a copy of the study(ies) along with supporting
workpapers and documentation. lf not, please explain why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 35: No. ldaho Power has
not conducted a study of lost revenues to the taxing districts along the proposed route
due to diminished property values.
ldaho Power notes that nearly all of the proposed overhead transmission line will
be located on public right-of-way, not private property. ln addition, most of the proposed
overhead transmission line will replace distribution lines already in place along the
proposed overhead transmission line route.
The response to this Request is sponsored by Ryan Adelman, Customer
Operations Projects Manager, Idaho Power Company.
DATED at Boise, ldaho, this 3d day of 17.
E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 51
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3d day of March 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KlKl LESLIE A. TIDWELL 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
47 2 W est Wash ington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, Idaho 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
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Kiki Leslie A. Tidwe!!
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
X Hand Delivered
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FAX
x Email daphne.huans@puc. idaho.sov
camille. christen@puc. idaho.qov
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 52
Kiki Leslie A. Tidwell
300 Let'er Buck Road
Hailey, ldaho 83333
_Hand DeliveredX U.S. Mai!
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Christa Bearry, Legal
City of Ketchum
Matthew A. Johnson
Wm. F. Gigray, III
WHITE PETERSON GIGRAY
& NICHOLS, P.A.
5700 East Franklin Road, Suite 200
Nampa, ldaho 83687
!ndividual
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
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 53