20170424IPC to Staff 13-17.pdf

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An IDACORP Company
DONOVAT{ E. WALKER
Lead Gounael
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Apd,l 24,2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
47 2 W est Washington Street
Boise, ldaho 83702
Re: Gase No. IPC-E-16-28
Certificate of Public Convenience and Necessity for Wood River Valley
ldaho Power Company's Response to the Second Prcduction Request of the
Commission Staff
Dear Ms. Hanian:
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the Second Production Request of the Commission
Staff.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to Staffs production requests.
ly yours,
Donovan E. Walker
DEW:csb
Enclosures
'122'l W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
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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Attomey 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
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CASE NO. !PC-E-16-28
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company'), and in
response to the Second Production Request of the Commission Staff to ldaho Power
dated April 3, 2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 13: Please provide cost estimates for the Company's proposed
line route across Dollar Mountain as described on page 19 of the Company's
Application. PIease include electronic workpaperc with allformulas and links intact.
RESPONSE TO REQUEST NO. 13: The cost estimate for ldaho Powe/s
proposed line route across Dollar Mountain is $21 ,482,982. Please see Attachments 1
through 5 provided on the enclosed CD for the supporting electronic workpapers with
formulas and links intact. This cost estimate is from July 14, 2014, and was a
preliminary estimate that was not continued forward as the other options were and is not
of the same conceptual Ievel as the other estimates. This cost estimate does not
contain any costs for easement acquisition or condemnation. Contained in this estimate
are costs to construct the section from Elkhom substation to Ketchum substation as a
double-circuit 138 kilovolt ("kV") line in the same alignment as the existing single-circuit
138 kV line, which would not require any new easements. However, there is no
practical way to keep the existing line energized while building a new double-circuit line
in the same location.
!nstead of a new double-circuit line in this section, the Company also looked at
building a new single-circuit line approximately 100 feet away from the existing line to
get physical separation, with only the last span double circuited. This "separation"
would require new easements flom Elkhom substation across Dollar Mountain to the
final span into Ketchum substation. ldaho Power does not have any curent estimates
for those easements, but a land value summary is provided as Attachments 3 and 4 to
the Company's response to the ldaho Public Utilities Commission Staffs ("Staff')
Request No. 14. The Company is concemed that a double-circuit line in the last span
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISS]ON STAFF - 2
into Ketchum substation would not perform reliably if constrained to the existing
easement, as it is a very long span. The Company initially investigated a separate route
for the new line from Dollar Mountain into Ketchum substation, and after several
meetings with landowners in the subdivision, it became clear that condemnation would
be the only way to get a separate line route.
The aftachments are summanzed as follows:
Attachment 1. Overall summary of Dollar Mountain route costs from
Wood River substation to Ketchum substation.
Attachment 2. Detailed summary of overhead 138 kV costs (transmission)
and distribution underbuild costs.
Attachments 3 through 5 are the supporting workpapers for Attachment 2.
Attachment 3. Map of transmission line estimate sections identifies two
separately estimated sections between the end of the Common Route and
Ketchum substation; Estimate File #1 as noted on the map is supported by
Attachment 4 and Estimate File #2 as noted on the map is supported by
Attachment 5.
The supporting workpapers for the station estimates (terminals and switches)
were supplied in the Company's Attachments 2 and 6 to Staffs Request No. 1.f.
The response to this Request is sponsored by Ryan Adelman, Transmission and
Distribution Projects Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 14: On page 19 of its Application, the Company explains that
the overhead transmission line route through the Ketchum Downtown District would
depend upon the condemnation of private property. Please provide the Company's
estimates of condemnation costs of the Overhead Transmission line route through the
Ketchum Downtown District.
RESPONSE TO REQUEST NO. 14: As stated in the Company's Application,
"Neither of the two possible route options for an Overhead Transmission construction
configuration [Dollar Mountain or Downtown District] provides a viable solution for
redundant electric service to the North Valley." Application at 20. As further explained
on pages 18-19 of the Application:
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. . . .
The line route across Dollar Mountain would be limited to a
double circuit on common tower configuration with the
existing 138 kV transmission line from Elkhom substation to
Ketchum substation. This common tower construction has a
high probability of resulting in the simultaneous loss of both
transmission circuits should a failure occur, resulting in North
Valley customer outages for the Line Events. This fact alone
defeats the purpose and need of constructing a redundant
source of energy to improve the reliability of service, and is
therefore not a viable option. Additionally, condemnation of
private property may be required to enter the Ketchum
substation overhead from Dollar Mountain. Finally, North
Valley customers would likely strongly oppose this option
due to the visual impacts. This option would not provide an
independent and fully redundant transmission source to the
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
Ketchum substations nor meet the purpose and need where
the other options discussed below would.
The Overhead Transmission line route through the Ketchum
downtown district would have significant challenges. The
challenges include the fact that the City of Ketchum is set up
with a grid of streets, sidewalks, and zero setback buildings.
Options that exist for construction of overhead transmission
include placing the poles in the sidewalks, the edge of
streets, and overhanging the wires over the streets,
constructing tall enough structures to span the wires over the
tops of buildings, and utilizing side streets. Because of the
very tight geographical constraints, this option would likely
be dependent upon and require condemnation of private
property in order to pass through downtown Ketchum with an
overhead line to the Ketchum substation. Again, North
Valley customers, in particular Ketchum customers, would
strongly oppose this option on visua! impacts alone.
However, ldaho Power has made some preliminary assessments of the potential
costs to be incuned in providing redundant electric service to the North Valley through
an overhead transmission option. The Overhead Transmission line route through the
Ketchum Downtown District would be located primarily in the public road right-of-way,
with the steel transmission poles located at the outer edge of the right-of-way. lf ldaho
Power were to use its TR (triangular) configuration for the 138 kV transmisslon line that
is proposed for other overhead portions of the transmission line (please see Attachment
1 provided on the enclosed CD), one of the transmission line insulators (approximately
five feet long) and the transmission line conductor attached at the end of the insulator
would extend out over the adjacent private property. This would require ldaho Power to
obtain an overhang easement over the private property for the insulator and conductor
along the length of the transmission line
As an alternative to the TR configuration, Idaho Power could employ a TA
(tangent angle) transmission line configuration where all three transmission line
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
insulators and conductors are placed on the road side of the power line (please see
Attachment 1). The TA poles (approximately 60 feet tall) are roughly 10 feet taller than
TR poles (approximately 50 feet tall) in order to provide sufficient spacing for the three
insulators and conductors on the same side of the pole. However, even with all three
insulators extending to the road side of the pole, the TA configuration could still require
overhang easements on the adjacent private property because there would not be
enough horizontal clearance from the conductors to a building constructed at the edge
of the adjacent private property (which would be possible with the zero setback
requirements in the Ketchum Downtown District).
ldaho Power has also reviewed engineering options for avoiding the transmission
line overhang and clearance requirements through the Ketchum Downtown District.
Idaho Power could add three cross-arms to make a modified TA configuration called a
"Davit Arm" structure in order to extend the three conductors further out into the road
right-of-way (please see Attachment 1). The Davit Arms would be approximately 12
feet long and each arm would have six-foot long insulators attached at the end of the
arm (to guide the energized conductor wire away from the end of the arm). ln some
cases this would cause the 12-foot arm plus the six-foot insulator extending directly out
from the arm to create a combined horizontal extension arm of 18 feet. This Davit Arm
configuration would eliminate the need for overhang easements or clearance space with
respect to the adjacent private propefi. However, the Davit Arm design is visually
more intrusive than the TR or TA designs as shown on Attachment 1. A photograph of
the Davit Arm configuration is also shown on Attachment 2 provided on the enclosed
CD. ldaho Power does not believe the Davit Arm design would be a viable option for
the overhead transmission line route through the Downtown District because the North
]DAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
Valley customers, in particular Ketchum customers, would strongly oppose this option
based on its visual impacts alone. Additionally, the placement of so many non-standard
structures in such close proximity to roads and zero setback buildings is simply not a
viable routing solution.
ldaho Power has not determined how many overhang easements on private
property would be required for the overhead transmission line route through the
Ketchum Downtown District under a TR or TA transmission line configuration. This
determination would require survey, design, and engineering of the route to establish
the specific locations of the transmission poles within the road right-of-way (or
potentially in some €ses, outside road right-of-way), followed by an assessment of the
overhang and clearance impacts of the transmission line on the adjacent private
property. However, ldaho Power did identify the private parcels adjacent to the
overhead transmission line route through the Ketchum Downtown District that could
possibly require overhang easements. A list of those parcels and their respective
assessed values are provided on the enclosed CD as Attachments 3 and 4,
Of the 20 properties identified in Attachments 3 and 4 related to the Downtown
District route, the assessed values range from a low of approximately $13,000 to a high
of approximately $2.6 million. Four of the 20 identified properties show a zero-assessed
value because they are Church-owned properties. The approximate total assessed
value of the remaining 16 properties exceeds $19.4 million. The estimated value of the
undeveloped land across Dollar Mountain is approximately $10/square foot. One
approximation for estimating the value of an easement is 50 percent of the market value
for the portion of the parcel required for the right-of-way. Under this approximation, the
estimated 100 foot wide easement cost for the two-mile portion across Dollar Mountain
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 7
is $5,420,000. The last span of Iine required of the Dollar Mountain route that enters
the Ketchum substation crosses four parcels in a developed residential subdivision in
Sun Valley. These parcels have a combined assessed market value of $7,31 1,248.
ldaho Power is unable to determine at this time what the easement valuation
would be for overhang easements crossing the parcels listed on Attachments 3 and 4
for the Downtown District route, and is unable to determine at this time what the
valuation of possible condemnation of required right-of-way would be valued at for
either the Downtown District route or the Dollar Mountain route. Relevant factors would
include the width of the easement strip, the existence of buildings or other
improvements within the easement strip, and the "severance" impact on the remainder
of the private parcel adjacent to the easement strip. Property owners could seek much
higher levels of compensation for the ldaho Power transmission line easements in a
condemnation proceeding. Condemnation damages are typically calculated based on
the value of the owne/s property before and after the condemnation taking. This
includes the diminution in value to the easement strip and also any "severance"
damages to the remainder of the owne/s property outside of the easement. In addition,
the property owner would seek to re@ver his or her legal expenses from ldaho Power
for the condemnation proceeding, which may or may not be recoverable depending on
the amount of the condemnation award compared to ldaho Power's final offer for the
easement acquisition. ldaho Power would also incur its own outside Iegal counsel
expenses for representation in the condemnation proceedings. Added to the potential
cost and liability of construction of transmission lines and structures in such close
proximity to tall buildings and other improvements upon the real property impacted
thereby, is the potential for claims of inverse condemnation, which could be very costly.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
Based on these multiple variables, ldaho Power cannot provide a meaningful estimate
of the cost of condemnation for either the Downtown District or the Dollar Mountain
route. However, based upon the nature of the structures and improvements that exist
on the parcels through downtown Ketchum and around the Ketchum substation, as well
as the very high assessed property values of the same, combined with an unknown
future but potentially costly liability associated with inverse condemnation claims, the
practicalities of actually obtaining the required easements, by condemnation or
otherwise, could be extremely costly and is simply not reasonable and prudent.
Because a more precise estimate of potential easement costs would require
significant additional work, cost, and evaluation (as stated above, this would require
among other things survey, design, and engineering of the route to establish the specific
locations of the transmission poles followed by an assessment of the overhang and
clearance impacts of the transmission line on the adjacent private property) and
because both overhead route options were determined to not be viable solutions for
redundant electric service to the North Valley, no further investigation of these costs
was done. The additional unknown costs of possible condemnation would not be
known with more certainty unti! the Company was at the point of actually pursuing
condemnation. Furthermore, the extent of exposure to possible claims of inverse
condemnation would be an additional potentially very costly liability moving forward after
such a line were constructed.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
REQUEST NO. 15: On page 19 of its Application, the Company explains that
the line route across Dollar Mountain may require condemnation of private property.
Please provide the Company's estimates of condemnation costs for the line route
across Dollar Mountain.
RESPONSE TO REQUEST NO. 15: Please see the Company's response to
Staffs Request No. 14 above.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1O
REQUEST NO. 16: ln case no. IPC-E-95-6, the Company requested that the
Commission amend CPCN No.272 to delete its authorization to construct a new 138 kV
transmission line from the Wood River substation to the Ketchum substation. In its
Application, the Company stated that it had conducted an extensive reassessment of
the feasibility and need for an additional 138 kV transmission, and had concluded that a
redundant line was not necessary. The Company stated that its reassessment included
structural, electrical, fire protection, and avalanche considerations. The Company also
stated that its actual 1994-1995 winter peak load was 55.5 MW, and that this was well
below the system's summer capacity limit. For the five year period trom 2012 through
2016, system peak has averaged 57.9 MW, or a 4.3o/o increase over the 1994-1995
winter peak load. Please answer the following questions:
a) What new information has caused the Company to determine that a
redundant 138 kV transmission line is now needed?
b) Please provide the results of any structural, electrical, fire protection, and
avalanche risks assessments that the Company has used to determine the need for a
redundant line.
c) Does the Company believe that the 4.3o/o increase in winter peak load is
sufficient to wanant the need for a redundant line?
RESPONSE TO REQUEST NO. 16:
a) The purcuit of a redundant transmission line from the Wood River
substation to the Ketchum substation was reestablished based on the: (1)
recommendation of the 2OO7 Community Advisory Committee, (2) increased age of the
existing transmission line which requires replacement of a substantial portion of the
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 11
structures, (3) avoidance of construction and then removal of a temporary line to
facilitate reconstruction of the existing line, and (4) increased fire hazard as evidenced
by the recent fire activity.
b) The Company has not performed or contracted any additional risk
assessments, other than the standard patrols, inspections, and repairs which clearly
show the deterioration of the lines and structures which are aged (constructed in 1962)
and need replacement.
c) The peak load of the Ketchum and Elkhom substations continue to exceed
the Company's 40 megawatt ('MW') threshold, requiring the addition of a second
transmission line to increase reliability for larger service areas.
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 THE COMM]SSION STAFF - 12
REQUEST NO. 17: ln its Application, the Company indicated that repairing the
existing system could require as many as 40 eight hour power intenuptions. To avoid
these intemrptions, the Company indicated the need for a second transmission line to
provide power while these repairs are made. Did the Company consider any routes that
would permit repair of the existing line without necessarily providing full redundancy? lf
so, please describe these routes and provide cost estimates. Please include electronic
workpapers with allformulas and links intact.
RESPONSE TO REQUEST NO. 17: The need for the second transmission line
to Ketchum is driven by an overarching need to provide reliable electric service to the
area. As part of that need, a second transmission line from Wood River substation to
Ketchum substation would accomplish two primary functions:
1. lt would provide a second source of electric power in the event the
existing transmission line fails for any unscheduled reason (i.e., fire, avalanche,
landslides, conductor icing events, structure failure, conductor failure, etc.). ln such an
event, the second line would provide an uninterrupted electrical source to the north end
of the Wood River Valley for a single point of failure on either transmission line.
2. The second transmission line would provide a second source of
electric power so that the existing transmission line could be temporarily removed from
service to perform maintenance, replace existing structures, and/or rebuild the line.
The 60 MW Ioad in the north end of the Wood River valley is divided between
two substations, with Ketchum substation serving approximately 48 MW of load and
Elkhorn substation serving approximately 12 MW. Idaho Power did have internal
discussions about a possible line route that would create a second line from Wood River
substation to Elkhom substation rather than the proposed Iine from Wood River to
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
Ketchum. Any altemative route that did not provide a second electrical source to
Ketchum substation was dismissed from consideration because any such option would
only provide the necessary reliability improvement to 20 percent of the customerc that
are at risk. Because any route that did not terminate at Ketchum substation was
dismissed from consideration, no estimates or planning for these routes was ever
conducted.
However, if a new line was to be built from Wood River to Elkhom, it would allow
the existing line to be temporarily de-energized to perform maintenance or structure
replacement on the existing line from Wood River substation to Elkhom substation.
This would provide some Ievel of reliability improvement for the 80 percent of customers
served by Ketchum substation and would provide significant reliability improvement for
the 20 percent of the load served by Elkhom substation. The approximate line mileage
from Wood River substation to Elkhorn is 10.4 miles and the mileage from Elkhom
substation to Ketchum substation is approximately 2.0 miles. !f a second source to
Elkhom substation rather than Ketchum substation were to be permitted, Idaho Power
could still perform maintenance and structure replacement on 84 percent of the total line
length that is in need of repair.
ldaho Power also consldered the option of building a temporary, overhead "shoo-
fly" line from Wood River substation to Ketchum substation. The shoo-fly would be
used to carry the power to the north end of the valley temporarily while the existing line
was rebuilt, presumably about two years. At the end of the rebuild project, the
temporary shoo-fly would be removed and the Ketchum and Elkhom substations would
continue to be fed by a single, radial source by the existing transmission line, as is the
case now. Although the shoo-fly would allow the existing line to be rebuilt to improve
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
reliability, this option was deemed an undesirable solution because of multiple reasons.
Among the reasons are:
1. There would a large investment in the shoo-fly, much of which
would be lost when the shoo-fly was removed.
2. The larye investment in the shoo-fly would not eliminate the
potential for future outages caused by a single event that could take out the existing
radial transmission line for extended periods.
3. The shoo-fly solution allows for cunent maintenance issues to be
addressed but does not allow for outages in the future to conect maintenance issues
that will develop later.
4. Most of the same siting issues associated with the permanent
downtown Ketchum overhead rcute would also impact the shoo-fly.
5. Some of the siting issues in Ketchum would actually be more
impactful for the shoo-fly. As an example, it would be difficult to justiff installation of
several steel, self-supporting angle structures costing $50,000 to $80,000 each for a
temporary line. The proposed permanent overhead route would utilize approximately
12 or more of these structures. Use of these same structures on the shoo-fly would
greatly increase the non-recoverable cost of this solution.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
DATED at Boise, ldaho, this 24h day of Apnl2017.
E. WALKE
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
CERTIFIGATE OF SERVICE
I HEREBY CERTIFY that on the 24h day of April 2017 I served a true and conect
copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Camille Christen
Deputy Attomeys General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6h Street
Boise, ldaho 83702
Sierra Glub
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. Tidwell
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
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camil le.christen@puc. idaho.gov
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISS]ON STAFF - 16
Kiki Leslie A. Tidwell
300 Let'er Buck Road
Hailey, ldaho 83333
Rolling Rock Properties, LLG, and
Rolling Rock Properties #2, LLC
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Rolling Rock Properties, LLC
Rock Rolling Properties, LLC
c/o Kris Dondero
P.O. Box 739
Sun Valley, Idaho 83353
Rolling Rock Properties #2, LLG
Rock Rolling Properties #2, LLC
c/o John Dondero
P.O. Box 739
Sun Va!!ey, ldaho 83353
City of Ketchum
Matthew A. Johnson
Wm. F. Gigray, lll
WHITE PETERSON GIGRAY
& NICHOLS, P.A.
5700 East Franklin Road, Suite 200
Nampa, ldaho 83687
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Email
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lndividual
Laura Midgley
231 Valley Club Drive
Hailey, ldaho 83333
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 17
GomGox, LLG
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
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Ch Bearry, Legal nt
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 18