20170331IPC to Tidwell 36-57.pdf

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DONOVAN E. WALKER
Lead Counsel
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Enclosures
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Donovan E. Walker
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An IDACORP Company
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
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March 31,2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 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 Second Production Request of
Kiki Leslie A. Tidwell
Dear Ms. Hanian
Enclosed forfiling in the above matter please find an originaland three (3) copies of
ldaho Power Company's Response to the Second 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 truly yours,
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 CONVENIENCE
AND NECESSITY FOR THE WOOD RIVER
VALLEY
CASE NO. |PC-E-16-28
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
KIKI LESLIE A. TIDWELL
COMES NOW, ldaho Power Company ("ldaho Powef' or "Company"), and in
response to the Second Production Request of Kiki Leslie A. Tidwell to ldaho Power
Company dated March 10,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 1
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REQUEST FOR PRODUCTION NO. 36: ln response to Request No. 8, Mr.
Angell responds that electrical demand in the North Valley varies with increased snow
making when concurrent with chair lift operations. Please document said statement by
providing peak load data (corresponding to the tables in response to Request No. 7) for
the time period beginning in 2000 for chair lift operations and snow making operations.
Please provide specific meter data in your response for each meter serving snow
making load and chair lift operation load. Please provide all documentation in support
of your response to Request No. 8.
RESPONSE TO REQUEST FOR PRODUCTION NO. 36: The information
requested is individualized customer meter, usage, personal, and/or financial
information. lndividualized customer information of the type requested is confidential
customer information that ldaho Power cannot disclose without the express consent of
the customer. Please provide the appropriate consent from the customer and Idaho
Power will release such information per the consent of the customer.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 2
REQUEST FOR PRODUCTION NO. 37: ln Request No. 2(C),ldaho Power was
asked to provide a complete list of "experienced sustained outage line events" for the
line referred to, which line was identified as "as a single-source radial line" that currently
serves the North Valley. The response identifies, inter alia, a 700-minute outage on
1212412009. The response to Request No. 13 provides a list of "all recorded outages on
the Wood River-Ketchum 138kV line 433 from 1995 to present". The referenced list
does not include the 7OO-minute outage that was included in response to Request No. 2
(C). Please reconcile this apparent discrepancy.
RESPONSE TO REQUEST FOR. PRODUCTION NO. 37: The 7O0-minute
outage on December 24,2009, was a sustained outage of the line due to the loss of
electric supply when both transmission lines serving the Wood River substation were
out of service due to inclement weather. This 70O-minute outage was inadvertently not
listed in the Company's response to Kiki Leslie A. Tidwell's Request for Production
No. 13.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 3
REQUEST FOR PRODUCTION NO. 38: Has ldaho Power considered any of
the following resources specifically for use in the North Valley. lf so, please document
said consideration. lf not please explain why each specific resource has not been
considered in the company's evaluation of the need for and/or the economiqs
associated with the construction of redundant line.
a. Demand Response - End Use Equipment Load Reduction
b. Demand Response - Behind-the-Meter Energy Storage
c. Stand-by Demand Response - Behind-the-Meter
d. Permanent Load Shift - Behind-the-Meter
e. Renewable Distributed Generation ("DG") - Behind the Meter
f. Renewable DG - in Front of the Meter
g. Energy Storage - ln-Front-of-the-Meter
h. Energy Storage - Behind-the-Meter
i. Solar PV DG paired with Energy Storage - Behind-the-Meter
j. Solar PV DG paired with Energy Storage - ln-Front-of-the-Meter
k. Combined Heat and Power
L Fuel Ce!!
RESPONSE TO REQUEST FOR PRODUCTION NO. 38: The additional
transmission line is required for reliable supply of electric service. Demand response or
load shift efforts will not alleviate the need and local generation is not as cost-effective.
Angell Exhibit No. 3 provided cost estimates for several local generation resources.
Please see the Direct Testimony of David M. Angell, p. 16.
O. What is the Company's conclusion from this analysis?
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 4
A.The report provides a high-level summary of the
Company's assessment of local backup generation
options. All of the options include higher initial and
ongoing maintenance costs compared to a redundant
transmission line alternative.
In response to other alternatives for the redundant transmission !ine, please see
the Direct Testimony of David M. Angell, pp. 18-19
o
A
What has ldaho Power concluded
investigation into alternatives for the
transmission line?
from its
redundant
Many of the alternative options suggested by the
KEAC or CAC are interesting and innovative;
however, they are technologies that are either cost
prohibitive or just not viable today. The Borrego
Springs microgrid demonstration project is a good
example of this. While the project was successful in
providing all of the electricity delivered to the Borrego
Springs community during a five and a half hour
preplanned operation, the Company does not believe
that this would be a viable cost-effective option for the
North Valley today. A simple extrapolation of the
project costs would suggest that if a 4.0 MW microgrid
cost $15 million at Borrego Springs, then a 60 MW
microgrid for the North Valley would cost $225 million,
or more importantly, for the 9,000 customers in the
North Valley, would cost approximately $25,000 each.
These alternative technologies are just not cost-
effective today, would only provide electric backup for
a relatively short period of time, and would still not
eliminate the need for the redundant transmission
system.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 5
REQUEST FOR PRODUCTION NO. 39: For each resource type listed in
Request No. 38 please provide all feasibility and economic studies in the company's
possession specific to said resource's use in the North Valley.
RESPONSE TO REQUEST FOR PRODUCTION NO. 39: Please see the
Northern Wood River Valley Local Backup Electrica! Supply Report, which can be found
in Angell Exhibit No. 3.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 6
REQUEST FOR PRODUCTION NO. 40: Please provide an inventory of all
existing emergency and/or back-up generators located in the North Valley. Please
include data relative to fuel usage, installation date, size and expected duration of
operation. What portion of the North Valley's peak load can be served through the use
of said back up and emergency generators? Please provide an inventory of all
emergency and/or back-up generators owned by ldaho Power Company that have been
retired from service that could have provided service to the North Valley.
RESPONSE TO REQUEST FOR PRODUCTION NO. 40: The Company does
not currently own any backup generators in the North Valley and does not inventory
customer generators that may operate independent of the ldaho Power system.
The Company retired a 50 megawatt ("MW') combustion turbine generator
located at the Wood River substation in 1992. lt was installed to provide system
peaking capacity and stability. lt was not configured to provide backup service to the
North Valley independent of the ldaho Power system. There are and were no other
emergency and/or backup generators owned by the Company.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIK] LESLIE A. TIDWELL - 7
REQUEST FOR PRODUCTION NO. 41: Please provide an inventory of all
energy efficiency and demand side management measures that have been installed in
the North Valley since 2000. Please break out all such measures installed at the Sun
Valley Resort and ski lift operations.
RESPONSE TO REQUEST FOR PRODUCTION NO. 41: Please see the Excel
spreadsheet provided on the enclosed CD which contains the end use measures,
participation, first year savings, and incentives paid to customers that have occurred in
Ketchum and Sun Valley from 2004-2016. ldaho Power's demand-side management
("DSM") database tracks DSM activities beginning in 2004. Between 2000 and 2004
ldaho Power offered three small residential energy efficiency programs funded by
Bonneville Power Administration, low income weatherization, and one commercial
education program in ldaho.
The spreadsheet shows Idaho Power's energy efficiency programs have paid
$889,365 in incentives and saved 7,783,281 kilowatt-hour ("kWh") first year savings in
Sun Valley and Ketchum between 2OO4 and 2016. ldaho Power paid incentives on six
projects (one project pending) for Sun Valley Company not at the ski Iift operations and
four projects at the ski lift operations.
ln addition to these incentives, the City of Ketchum participated in ldaho Power's
Wastewater Energy Efficiency Cohort ("\ M/EEC"), which started in 2014. The cohort
has provided hands-on energy efficiency and energy management training to the City's
wastewater and public works professionals. Under the guidance of the cohort, it formed
an energy team, set energy goals, and established an energy policy for its organization,
to assure persistence of the energy savings. The behavior changes by the City's
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 8
wastewater and public works professionals combined with capital projects in the two
years of the cohort have saved over 37 percent of their average monthly usage at the
wastewater treatment plant.
Beginning in 2016, the City of Ketchum participated in a second cohort, ldaho
Power's Water Supply Optimization Cohort ('WSOC'), this cohort focused on the clean
water supply side of the City's service. The goal of the WSOC is similar to the
\ A/VEEC, to equip water professionals with hands-on training to help operators
efficiently manage their systems while improving energy efficiency.
Although it is not possible to segregate the number of bulbs and energy savings
provided to the North Valley by the ldaho Power-sponsored retail buy downs, Sun
Valley and Ketchum customers have benefited from residential efficient lighting
programs that reduced the purchase costs of both compact fluorescent lamp (CFL) and
light-emitting diode (LED) light bulbs that have been available through retail
establishments in Twin Falls since 2005. Buy down bulb sales through Twin Falls
retailers have totaled over 900,000 bulbs with over 12.5 million kWhs of savings.
The Community Schoo! in Ketchum received a 4 kilowatt solar installation that
was funded by ldaho Power's Green Power customers through the Solar 4R Schools
program.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 9
REQUEST FOR PRODUCTION NO. 42: Please provide population data on an
annual basis for the North Valley from 2000 to current.
RESPONSE TO REQUEST FOR PRODUCTION NO. 42: ldaho Power does not
track population data for specific geographic regions.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 1O
REQUEST FOR PRODUCTION NO.43: ln response to Request No. 21[sic] the
Company states that the Osmose fire protection coating was applied in 1994 and that
the "coating is advertised to protect the wood poles from fire for two-three burn cycles."
According to the response, none of the poles have been exposed to fire since the
coating was applied in 1994. What is the life expectancy of the fire coating in terms of
years absent exposure to fire?
RESPONSE TO REQUEST FOR PRODUCTION NO. 43: ldaho Power has no
additional information on the life expectancy of the Osmose Fire Guard product other
than that already provided in the Osmose literature supplied in the Company's response
to Tidwell's Request for Production No.21[sic]. ln that Iiterature, the manufacturer
states, "The latex based formula provides excellent flame resistance and can withstand
years of outdoor weathering." The same literature also states, "Long-lasting - When
applied properly, Fire-Guard coating can withstand years of outdoor weathering and
typically 2 to 3 burn incidents, depending on intensity and duration of the burn."
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 11
REQUEST FOR PRODUCTION NO. 44: Please provide all information in your
possession that relates to or mentions Ms. Tidwell, please include all information that
relates to her role as a holder of lda Corp/ldaho Power securities.
RESPONSE TO REQUEST FOR PRODUCTION NO. 44:. Please see
Attachments 1-15 provided on the enclosed CD for the requested information that
relates to the mention of Ms. Tidwell that is not attorney-client privileged or attorney-
work product.
IDACORP, lnc. ("IDACORP') does not show Ms. Tidwell as a current registered
holder of IDACORP common stock. !f Ms. Tidwell owns shares of IDACORP common
stock through a broker or other nominee, those shares would be registered under the
broker or nominee name and not under Ms. Tidwell's name. IDACORP's Annual
Meeting attendance records indicate that Ms. Tidwell signed in for attendance at the
May 20,2009, IDACORP Annual Meeting.
ldaho Power needs additional time to identify and review communications
relevant to this Request for Production. ldaho Power will file a supplemental response
to this Request for Production within an additional 10 days, by April 12,2017 .
The response to this Request is sponsored by Pat Harrington, Corporate
Secretary, Idaho Power Company, and David Angell, Transmission and Distribution
Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 12
REQUEST FOR PRODUCTION NO. 45: Please, provide copies of all material
used in selecting and/or recruiting the Community Advisory Committees ("CAC').
Please include a copy of all correspondence and other communications with all CAC
members and/or potential members.
RESPONSE TO REQUEST FOR PRODUGTION NO. 45: Please see the
internal meeting minutes document provided on the enclosed GD where selection and
recruitment were discussed (Attachment 1). The video titled Building an "Electricity
Highway" for the Wood River Valley - January 2007 was used to invite membership and
can be viewed via the following link:
https://www.idahopower.com/AboutUs/PlanningForFutureiReqionalElectricalPlansMoodRiver/videoNews.cfm.
The invitation brochure and acknowledgment letter are provided on the enclosed
CD as Attachments 2 and 3. All agendas, presentations, and meeting minutes are
publicly available on ldaho Power's website and can be viewed via the following link:
https://www.idahopower.com/AboutUs/PlanningForFuture/ReqionalElectricalPlansAlVoodRiver/default.cfm.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 13
REQUEST FOR PRODUCTION NO. 46: Please explain whether the CAC
conducted an independent evaluation of the options available to ldaho Power with
regard to the need for the proposed line. Please provide the resumes and qualification
statements for each member of the CAC.
RESPONSE TO REQUEST FOR PRODUCTION NO. 46:Options were
discussed in meetings with the CAC and the CAC made recommendations based on
ldaho Power's evaluation of the options developed from these meetings. ldaho Power
does not have resumes or qualification statements for each member of the CAC beyond
the jurisdictions or organizations that they represent.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 14
REQUEST FOR PRODUCTION NO. 47: Please list all members of the CAC
who own property that is adjacent to or within 1,000 feet of the proposed line. For each
such member please note the physical address of the subject property.
RESPONSE TO REQUEST PRODUCTION NO. 47:ldaho Power is
concerned with singling out any specific members of the CAC, all of whom served
without compensation. ldaho Power is not specifically aware of the land ownership
status of the members of the CAC. Blaine County land ownership information is publicly
available through the Blaine County Assessor's Office and/or the Blaine County
Recorder's Office.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 15
REQUEST FOR PRODUGTION NO. 48: Please provide copies of all
communications between the Sun Valley Company and ldaho Power regarding the
proposed redundant transmission line. Please provide al! documents in ldaho Power's
possession mentioning the provision of electrical service to the Sun Valley Company
and/or the proposed redundant transmission line.
RESPONSE TO REQUEST FOR PRODUCTION NO. 48: ldaho Power received
a copy of the letter provided on the enclosed CD from the Sun Valley Company to the
Blaine County Planning and Zoning Commission. ldaho Power needs additional time to
identify and review communications relevant to this Request for Production. ldaho
Power will file a supplemental response to this Request for Production within an
additional 10 days, by April 12,2017.
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 SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 16
REQUEST FOR PRODUCTION NO. 49: Please provide documentation of any
electric utility industry standards or prudent utility practices as they relate to the siting of
redundant transmission lines.
RESPONSE TO REQUEST FOR PRODUCTION NO. 49: The Company is
unaware of any written documentation of electric utility industry standards related to the
siting of redundant transmission lines. Many factors are considered in siting of
redundant lines, including terrain, federal and local permitting, easements,
constructability, and cost.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Gompany.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 17
REQUEST FOR PRODUCTION NO. 50: Please provide a map showing the
distance, in linear feet, between the existing transmission line and the redundant
transmission line between the Wood River Substation ('WRS') and the point north of
the golf club where the existing line veers to the northeast.
RESPONSE TO REQUEST FOR PRODUCTION NO. 50: Please see the map
provided on the enclosed CD.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 18
REQUEST FOR PRODUCTION NO. 51: Please explain the apparent
inconsistency of sourcing redundant transmission lines from a single common
substation. Please also explain the apparent inconsistency of siting redundant
transmission lines along a parallel path from the Wood River Substation to just north of
the golf club. Please explain and document the added reliability the use of a common
substation and parallel paths (from the WRS to the golf club) provides the North Valley.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5,l: The ind ustry-expected
outage frequency for a transmission substation can range from once in eight to once in
15 years, depending on the configuration. The industry-expected outage frequency for
a 138 kilovolt ("kV') transmission line is once in two years. The construction of a
redundant transmission line changes the outage frequency to once in 3000 years.
ldaho Power has proposed the new transmission line in a separate corridor and
reconfigured the existing transmission line route to avoid one line crossing the other.
This proposal maintains separation between the two lines for all but a short section.
The short section within a common corridor increases the expected outage frequency;
however, it is expected to occur less frequently than a substation outage. Table 1
contains the outage frequency expressed in Mean Time Between Failures as computed
by the General Reliability SUBREL computer program.
Table 1. Substation and Transmission Line Outage Frequencies
Gonfiguration 4 Breakers -
Single Bus
4 Breakers -
Ring Bus
Single
Line
Two
Lines
Mean Time Between
Failures (years)7.9 15.4 2.3 3003
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 19
REQUEST FOR PRODUCTION NO. 52: Please identify all current or former
officers or directors (or their immediate family members) of ldaho Power Company, lda
Corp or any of its subsidiary companies who own, directly or indirectly, real property in
the North Valley. Please provide the physical address for each such parce! owned.
Please provide the same information for all individuals (and their immediate family
members) or entities with a five percent or more equity interest in ldaho Power, lda
Corp or any of its subsidiary companies.
RESPONSE TO REQUEST FOR PRODUCTION NO. 52: ldaho Power does not
possess the requested information regarding land ownerships in Blaine County by all
current or former officers or directors or their immediate family members or by entities
with a five percent or more equity interest in Idaho Power, IDACORP, or any of its
subsidiary companies or their immediate family members. Blaine County land
ownership information is publicly available through the Blaine County Assessor's Office
and/or the Blaine County Recorder's Office.
The response to this Request is sponsored by Pat Harrington, Corporate
Secretary, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 20
REQUEST FOR PRODUCTION NO. 53: Please identify by physical address all
real property owned by Idaho Power, Ida Corp or any of its subsidiary companies
owned in the North Valley that is not currently used and useful in the provision of retail
electrical service.
RESPONSE TO REQUEST FOR PRODUCTION NO. 53: To the best of the
Company's knowledge, ldaho Power, IDACORP, or any of its subsidiary companies do
not own land in fee in the North Valley that is not currently being used for retail electrical
service.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 21
REQUEST FOR PRODUCTION NO. 54: Has ldaho Power conducted a
structura! reliability and risk assessment study of the existing transmission line since
1993. If so, please provide a copy and all associated workpapers. lf not please explain
why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 54: Please see the
Company's response to Tidwell's Request for Production No. 20. ln that response, the
Company states:
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 physica! 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.
The response to this Request is sponsored by David Angel!, Transmission and
Distribution Planning Manager, ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIK] LESLIE A. TIDWELL - 22
REQUEST FOR PRODUCTION NO. 55: Does ldaho Power have plans to
upgrade the existing transmission !ine? lf so please provide copies of those plans along
with al! associated workpapers. lf not, is it ldaho Power' plan to abandon the existing
transmission line?
RESPONSE TO REOUEST PRODUGTION NO. 55:ldaho Power planning
studies show that the power flow capacity of the existing Wood River-Ketchum line is
sufficient to provide for the electrical demands of the area served by the line for the
ultimate future build-out of the area at the north end of the Wood River Valley. ldaho
Power does not plan to upgrade the voltage level or current carrying capacity of the
existing Wood River-Ketchum 138 kV line. lf the second line from Wood River to
Ketchum is built as proposed, it would allow the existing 1962 vintage Wood River-
Ketchum 138 kV !ine to be de-energized during planned periods to facilitate
replacement of insulators, crossarms, and structures.
ldaho Power does not plan to abandon or remove the existing Wood River-
Ketchum transmission line (circa 1962), if and when the second Wood River-Ketchum
transmission line is built and placed into service. To the contrary, two 138 kV
transmission lines are needed from Wood River to Ketchum to provide prudent electrical
service reliability. ln addition, having two sources of electrical supply to Elkhorn and
Ketchum substations would allow either of the lines to be removed from service
temporarily to allow for future maintenance projects on either transmission line in a safe
and efficient manner.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 23
REQUEST FOR PRODUCTION NO. 56: Please reconcile the small number and
short duration of outages experienced in the prior rerouting of the existing line with the
expected larger number and longer duration of outages to reconstruct the existing Iine.
RESPONSE TO REQUEST FOR PRODUCTION NO. 56: ln 1 994, Idaho Power
relocated approximately 1.5 miles of the existing Wood River-Ketchum 138 kV
transmission line 433 north of Wood River substation at the request of the Valley Club
developer. ln order to accomplish the relocation of the line segment while minimizing
outages to ldaho Power's customers, Idaho Power built a separate, temporary "shoo-fly"
west of the existing line to reroute power around the project site during construction.
Think of this "shoo-fly" as a way to route power around a specific location, in the same
way that a road detour takes traffic along a temporary route to allow a specific road
section to be shut down for construction purposes. Once the "shoo-fly" was built, a
short line outage was taken on the transmission line to allow the north and south ends
of the "shoo-fly" to be electrically connected to the main transmission line. At the same
time, open points were created in the main line's wire, just south of the north "shoo-fly"
connection and just north of the south "shoo-fly" connection. This was done by
removing jumpers at existing dead-end structures, where breaks in the wire already
existed. The line was then re-energized, which energized the "shoo-fly." This
arrangement allowed the power to flow around the project site via the "shoo-fly," while
keeping the existing line section between the open points de-energized. ln this way, the
power flow from the Wood River substation to the Elkhorn and Ketchum substations
was maintained while the 1.5 mile relocation segment remained de-energized
throughout construction. The new line segment was then built along the new route
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 24
further to the east and the existing H-frame line between the open points was removed.
Once the line was relocated to the east and was complete, another short outage was
taken to disconnect the "shoo-fly" from the main line and connect the relocated section
to the main line. Using this method, only two short outages were needed.
!n order to replace all of the dead-end structures and some of the tangents in
between the Wood River and Ketchum substations, it would be necessary to de-
energize the line without the benefit of having a "shoo-fly" or bypass to route the power
around the job sites. Because the structure replacement locations are spread out over
12 miles of line route, it is not practical or feasible to build a "shoo-fly" around this much
line to allow it to be de-energized in the fashion used on the Valley Club relocation
project. The alternative is to simply take the existing line out of service, which creates
the outages. lt is estimated that it will take a full day for a crew to replace each of the
dead-end structures and those tangent structures where access is limited along the
existing route. !n order to ensure worker safety, the line must be de-energized during
the structure replacement process for the dead-end and tangent structures identified.
This is why the Company expects a large number of extended customer outages to
rebuild the existing line in absence of a second, new 138 kV transmission line to feed to
the north end of the Wood River Valley during the reconstruction.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 25
REQUEST FOR PRODUCTION NO. 57: Please specifically identify the costs of
undergrounding the line through the North Valley and specifically compare those costs
to the least cost overhead option through the North Valley. Please explain who wi!! pay
any costs of undergrounding that are in excess of the least cost overhead option. !f the
additional costs of the undergrounding option will be paid for by ldaho Power ratepayers
in general, please quantify the cost increase on the average residential customer.
RESPONSE TO REQUEST FOR PRODUCTION NO. 57: The costs of
undergrounding the transmission line are provided in the Application in Exhibit No. 7.
The least-cost overhead option through the North Valley is the Overhead Distribution,
identified as the base case. Costs for this option are also included in Exhibit No. 7. The
proposed project, Underground Transmission-TP1, is economically equivalent to the
base case; therefore, no incrementa! cost allocations are necessary. However, should
Underground Transmission TP2 or TP3 be required to be constructed by the local
jurisdictions, then the Company has asked the ldaho Public Utilities Commission that
the incremental cost difference be assessed to the cities of Ketchum and Sun Valley
and to Blaine County.
The response to this Request is sponsored by Mike Youngblood, Regulatory
Projects Manager, ldaho Power Company.
DATED at Boise, ldaho, this 31't day of March 2017.
t44)
DONOVAN E.
Attorney for Idaho
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 26
Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 31" d"y of March 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
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 Conseruation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
Zach Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Kiki Leslie A. Tidwel!
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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camille. christen@puc. idaho.oov
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 27
Kiki Leslie A. Tidwell
300 Let'er Buck Road
Hailey, ldaho 83333
City of Ketchum
Matthew A. Johnson
Wm. F. Gigray, lll
WHITE PETERSON GIGRAY
& NICHOLS, P.A.
5700 East Franklin Road, Suite 200
Nampa, Idaho 83687
lndividual
Laura Midgley
231 Valley Club Drive
Hailey, ldaho 83333
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Christa Bearry, Legal Assista
GomGox, LLG
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 SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 28