20170428IPC to Sierra Club 1-21.pdf

S!ffi*.
An IDACORP Company
DONOVAN E. WALKER
Lead Counsel
dwalker@idahooower. com
April2T , 2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
!daho 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 ldaho
Sierra Club
Dear Ms. Hanian
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the First Production Request of ldaho Sierra Club.
Ve ly
Donovan E. Walker
DEW:csb
Enclosures
1221 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
Attorney for ldaho Power Company
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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. IPC-E-16-28
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
IDAHO SIERRA CLUB
COMES NOW, ldaho Power Company ("ldaho Power" or "Comp?ry"), and in
response to the First Production Request of ldaho Sierra Club to ldaho Power Company
dated April 6, 2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 1
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REQUEST FOR PRODUCTION NO. 1: The Application states that the existing
138 kV radial transmission line in the North Valley will require reconstruction and that
such reconstruction "is required whether or not a redundant transmission line is
constructed." Application at 16. Please provide the Company's estimate for the costs
of reconstructing the existing line, as well as the Company's plan for recovering those
costs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: No design work has
been performed on the reconstruction of the existing transmission line, nor have any
detailed cost estimates been developed for the reconstruction of the existing Wood
River-Ketchum 138 kilovolt ("kV') transmission line. Also, the degree of reconstruction
for the existing line has not been fully scoped. However, two preliminary cost estimates
have been prepared, assuming the project would require a complete line rebuild
(conductor and structure replacement). Those two preliminary cost estimates and the
nature of the projects are described in the attached document. ln addition, the
document talks about a third method to accomplish the rebuild by doing the work on an
energized line. This third "hot" method is not estimated and the reasons for this are
explained in the document.
While the Company has not developed a specific plan for recovering costs
associated with reconstruction of the existing line, at this time, it is anticipated that these
costs will be recorded to electric plant-in-service in the same manner as other capital
projects for inclusion in a future rate filing. However, if incremental costs are incurred
related to non-standard construction (e.9., building a temporary line to accommodate
line reconstruction due to local opposition to permanent redundant service), the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB.2
Company may consider directly assigning these costs to the local jurisdictions
responsible for the incurrence of these costs.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company, and Tim Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 3
REQUEST FOR PRODUCTION NO. 2:The Application states that
reconstruction of the existing line will involve replacing the existing wood structures with
steel structures in approximately the same locations. Application at 17. Could replacing
the existing wood structures with steel structures provide greater resiliency to outages
caused by avalanche, ice loads, fire or micro-burst winds? Please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Simply replacing the
existing wood structures with steel structures does not ensure they will have a higher
structural capacity. There are steel poles available that have lower strength than some
wood poles that are common and readily available. The existing wood poles' structural
capacity has degraded over time as they have aged. The existing wood structures on
the Wood River-Ketchum line do not have the same capacity they had at the time the
line was built in 1962. The National Electric Safety Code ("NESC") allows for and takes
into account this wood degradation in establishment of its strength criteria. lf the
existing conductor is replaced during the reconstruction, the new structures would need
to have a higher strength capacity in order to meet the NESC requirements generated
by the larger and heavier conductor. lf the existing conductor is not replaced, it is
possible and likely that the proposed steel structures would still have a higher structural
capacity than the existing wood structures. Additionally, ldaho Power would take into
account known threats to the line, such as conductor icing and avalanche, during the
design process of the reconstruction. This would further increase the structural capacity
of some of the new structures beyond those of the existing line.
Steel structures would eliminate the threat of two of the hazards experienced by
the existing line. Those two threats are structure damage from wildfire and
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 4
woodpeckers. Neither of these threats would affect the new steel replacement
structures. The new steel replacement structures could be designed to mitigate the
threat from weather events such as avalanche, micro-burst wind, and ice loading but
these threats cannot be eliminated. ln particular, because of the extreme nature and
unpredictability of avalanches, it is impossible to design structures that are entirely
avalanche resistant. Threat from micro-burst winds and extreme icing events can also
be mitigated but not completely eliminated. ldaho Power engineering will use its
experience and knowledge to minimize the threats to the reconstructed line to the extent
practical. The reconstructed line would be more resilient to the threats outlined above,
but there would still be significant risk without a second transmission source to the
Ketchum substation.
The response to this Request is sponsored by Ryan Adelman, Transmission and
Distribution Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 5
REQUEST FOR PRODUCTION NO. 3: David Angell's Direct Testimony states
that the Company responded to its inability to build a third 138kV line in the South
Valley by upgrading the existing King-Wood River line with "new larger conductor and
steel towers." Angell at7-8. By what amount could the capacity of a new line on the
existing WDRI-KCHM route be increased by using a "new larger conductor" rather than
the #410 (Penguin) ACSR conductors with a few spans supporting 397.5 kcmil (lbis)
ACSR conductors that are currently being used on that line?
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The existing WDRI-
KCHM transmission line, with a 127 MVA winter capacity rating, has sufficient capacity
to serve the present and forecasted peak load of the North Wood River Valley
customers. The redundant transmission line is needed to serve the area load during
planned and unplanned outages.
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 FIRST
PRODUCTION REOUEST OF IDAHO SIERRA CLUB - 6
REQUEST FOR PRODUCTION NO. 4: Please provide the Company's estimate
for the costs of building the temporary transmission line described in David Angell's
Direct Testimony on pages 22-23, taking into account the costs that would be recouped
by salvaging the majority of the poles and insulators.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: The Company's initial
estimate, including credit of salvageable materials, for building a temporary, overhead
"shoo-fly" line from Wood River substation to Ketchum substation to rebuild the existing
line was $4 million. However, this option was deemed an undesirable solution because
of the reasons specified in the Company's response to the ldaho Public Utilities
Commission ("Commission") Staff's ("Staff') Production Request No. 17.
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 7
REQUEST FOR PRODUCTION NO. 5: ln the 2011 Wood River Electric Plan,
ldaho Power projected that in Year 15 it would be necessary to "add new voltage control
device at Ketchum substation." Exhibit No.2 to David Angell's DirectTestimony at77
of 92, Appendix H. What does the Company project will cause the need for
improvement to voltage control at the substation in that timeframe? What devices might
meet these needed improvements?
RESPONSE TO REOUEST FOR PRODUCTION NO.The Company
forecasts the peak load served by the Lincoln, Silver, Hailey, Ketchum, Elkhorn,
Moonstone, Toponis, and Pocket substations to increase to a point requiring additional
voltage support at the Ketchum substation in order to supply proper voltage to the
customers served by Ketchum and Elkhorn substations. The Company plans to install a
shunt capacitor bank, which may be switched into service during the peak loading
conditions, to increase the voltage at the Ketchum and Elkhorn substations.
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB.8
REQUEST FOR PRODUGTION NO. 6: Are there any other distribution lines
running from the Ketchum or Elkhorn substations beside the following
EKHN-o11
EKHN-012
KCHM-o11
KCHM-o12
KCHM-o13
KCHM-014
KCHM-o15
KCHM-o16
KCHM-o17
Please provide a map of showing the areas served by each of the distribution lines
running from the Ketchum and Elkhorn substations.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: There are no other
distribution circuits from Ketchum or Elkhorn substations. Please see the attached map
for the areas served by each distribution circuit.
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 9
REQUEST FOR PRODUCTION NO. 7: How many transformers for reducing
voltage from the 138kV transmission line level to distribution line voltage level are
present in the Ketchum substation? !n the Elkhorn substation?
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: There are two
transformers at the Ketchum substation and two transformers at the Elkhorn substation.
The response to this Request is sponsored by David Ange!!, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB. 1O
REOUEST FOR cTtoN No. 8: The table below lists some outages
experienced on the existing WDRI-KCHM 138kV line (data taken from ldaho Power's
response to Tidwell's Request for Production No. 13). Please provide the load being
served from the Ketchum and Elkhorn substations immediately preceding each outage.
Date Duration Cause
5t31195 104 Maintenance
8t14t98 5 Unknown
1t1to4 10 Weather
10t11t04 108 Maintenance - Vandalism
2t18105 58 Equipment Failure
9t27111 342 Maintenance
8112t14 126 Lightning
10113t15 465 Maintenance - Woodpecker
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: Load data for the first
two outages is unavailable because the Company only maintains data back to 2000.
Please refer to the table below for the load data immediately preceding each outage.
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 11
Date Duration Cause Ketchum Load Elkhorn Load
5131t95 104 Maintenance Unavailable Unavailable
8t14198 5 Unknown Unavailable Unavailable
1t1lo4 10 Weather 33.1 MW 7.4 MW
10t11t04 108 Maintenance - Vandalism 10.8 MW 3.1 MW
2t18tO5 58 Equipment Failure 28.5 MW 6.7 MW
9t27t11 342 Maintenance 9.5 MW 2.0 MW
8t12t14 126 Lightning 16.3 MW 5.3 MW
10t13t15 465 Maintenance - Woodpecker 10.6 MW 4.0 MW
REQUEST FOR PRODUCTION NO. 9: Please describe the Company's plans
for serving the North Valley in the event the reconstructed line and potential new
redundant line experience outages at the same time due to "Line Events" or other
causes such as that which resulted in the December 2009 loss of power to the WDR!
substation.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: ln the low probability
event that both lines sourcing the North Valley experience outages at the same time or
there is a loss of power to the Wood River substation, the Company will restore service
as quickly as possible following prudent utility practices of testing, isolating failed
device(s), restoring the remaining system, and repair or replacement of the failed
device(s).
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 12
REQUEST FOR PRODUCTION NO. 10: Please describe each time the
Company has relied upon a Certificate of Public Convenience and Necessity to preempt
local restrictions on siting of utility infrastructure.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: The Company is not
aware of any time that it has relied upon a Certificate of Public Convenience and
Necessity to preempt local restrictions on siting of utility infrastructure.
The response to this Request is sponsored by Michael Youngblood, Manager
Regulatory Projects, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - ,I3
REQUEST FOR PRODUCTION NO. l1: Please describe each time the
Company has imposed incremental costs (i.e. costs in addition to the Company's
lowest-cost base case due to local preferences such as underground burial of
transmission lines) on local customers and the lega! mechanisms used to allocate these
costs. This question includes but is not limited to costs associated with underground
burial of transmission lines.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: ldaho Power has not
imposed any incremental costs due to local preferences on its local customers.
However, to the extent that communities (cities/counties) desire the Company to pursue
alternate designs, such as underground transmission at a higher cost, it is the
Company's position, as previously supported by the Commission in Case No.
IPC-E-04-04, Order No. 29634, that the community requesting and benefiting from the
alternate design is responsible for the incremental cost differential between the least-
cost standard practice option and the desired option. To collect funds for these
incremental costs, the cities/counties may use the Underground Conversion of Utilities
Law, ldaho Code S 50-2501, ef seg., which authorizes and provides a method for cities
to convert overhead electrical facilities to underground locations or to place new
electrical facilities u nderground.
The response to this Request is sponsored by Michael Youngblood, Manager of
Regulatory Projects, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 14
REQUEST FOR PRODUCTION NO. 12: When im posing incremental costs on
local communities, please describe whether and how the Company distinguishes
between users when deciding how to allocate those costs. For example, has the
Company ever allocated more costs to users based on the quantity or timing of their
load?
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: Please see the
Company's response to ldaho Sierra Club's Request for Production No. 11.
The response to this Request is sponsored by Michael Youngblood, Manager
Regulatory Projects, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 15
REQUEST FOR PRODUCTION NO. 13: ln Figure 2 of Appendix C of the
Northem Wood River Valley - Local Backup Electrical Supply Report (the City of
Ketchum So/ar Generation Assessmenf), the Company shows the City of Ketchum load
on December 23, 2014. Please provide a figure, in similar format, showing both City of
Ketchum load and total Ketchum substation load for that same day.
RESPONSE TO REOUEST R PRODUCTION NO. 13:The figure below
shows the total load at the Ketchum substation and the total load in the City of Ketchum
on December 23,2014.
1.2l23l20t4 City of Ketchum Load vs Ketchum Substation Load
3
=
Hour
r Kctdrum Substltlon r Clty of !(ctchum
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 16
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30
25
20
15
10
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o l 2 t 4 5 5 7 I 9 10 lr 12 13 t4 15 15 L7 18 19 20 2L 22 23 24
REQUEST FOR PRODUCTION NO. 14: ln response to Commission Staffs First
Request for Production No. 1(e), the Company stated that it "regularly installs tie
switches between distribution circuits to provide alternate service to restore customers
during substation and circuit outages." Also in Mr. Adelman's Direct Testimony (at 17),
he states that the Company "implement[s] distribution circuits with tie switches" as a
"standard practice to reduce sustained outages and improve system reliability." Both
the overhead and underground distribution options in the Application would require the
building of a new transmission line, a new substation and up to five new distribution
lines in order to be able to connect to existing Elkhorn and Ketchum distribution lines via
tie switches. Please provide examples of instances where the Company has built a new
transmission !ine, a new substation, and up to five new distribution lines in order to be
able to implement its standard practice of linking distribution lines via tie switches as a
mechanism for reducing sustained outages.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14:The Company has
installed 1,862 three-phase tie switches for the more than 630 distribution circuits that it
operates. The table below provides three examples of tie switches that were installed
with recently constructed substations. Each substation required construction of a new
transmission line and distribution circuits with multiple tie switches to Iink the new
distribution circuits to existing distribution circuits, supplied by existing substation, to
reduce the duration of sustained outages for customers in the event of long-duration
outages on the new transmission line or substation.
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 17
Substation Location Number of
Distribution Gircuits
Number of Three-
Phase Tie Switches
Number of Other
Tie Switches
Pole Line Twin Falls, lD 3 6 2
Star Star, lD 4 5 4
Stoddard Meridian, lD 3 10 5
REQUEST FOR PRODUCTION NO. 15: ln his Direct Testimony (at 15-16), Mr.
Angell stated that the ldaho National Laboratory ('lNL") "provided independent review
and feedback" on the Company's distributed generation alternatives analysis. The
Company further detailed INL's input in response to Commission Staffs Request for
Production No. 7. Please provide emails, notes, or other records from any
conversations with Kurt Myers of lNL, or any other INL employee, on the following
topics:
1. Did INL provide any comments regarding designing backup for rare
outages by focusing on backing up critical load rather than total load?
2. Did INL provide any comments regarding providing differing levels of
reliability for different types of loads?
3. Did INL provide any comments regarding analyzing the use of a single
large natural gas fired turbine generator rather than combining the smaller and lower
cost reciprocating engine (e.9. Wartsila) units that are analyzed in the Company's
lntegrated Resource Plan?
4. Did INL provide any comments regarding the range of Idaho Power's
current and future cost estimates for battery storage?
5. Did INL provide any comments regarding the Company's decision to
evaluate one alternative energy resource at a time (i.e. assuming that the one
alternative energy resource would be responsible for providing backup for the entire
load)?
Please also provide any analysis the Company has done for scenarios where any of
these alternative energy resources were evaluated in combinations with one another.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 18
RESPONSE TO REQUEST FOR PRODUGTION NO. 15:
1. No. The Company evaluated the requirements for property protection,
defined as the demand required to maintain building heat at a level to avoid freezing
water pipes during sub-zero temperature conditions. The results of this analysis were
included in David Angell's testimony Exhibit No. 3, beginning on page 17.
2. No. Please refer to the Company's response to subpart 1 above.
3. No because the report included both a combustion turbine and
reciprocating engine options. Please refer to David Angel!'s testimony Exhibit No. 3,
beginning on page 5.
4. The INL comments and notes were provided in the Company's response
to Staff's Production Request No. 7.
5. No. The Company did include several resource combinations in the
HOMER modeling. However, the report included in David Angell's testimony Exhibit
No. 3 identified a preliminary cost estimate for each resource option to provide insight to
the cost relative to one another.
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 19
REQUEST FOR PRODUCTION NO. 16: ln the Executive Summary of the
Northem Wood River Valley - Local Backup Electrical Supply Report, the Company
characterizes its study and estimates as "preliminary and conceptual in nature." Exhibit
3 to Angel!'s Direct Testimony at 9 of 56. See a/so Angell al 14 and 16 (characterizing it
as a "preliminary and conceptual investigation" and "a high-level summary",
respectively). Mr. Angel! also stated, "ldaho Power would need to take part in extensive
design and engineering work to provide more detailed estimates." Exhibit 3 to Angell's
Direct Testimony at 3 of 56. Please describe any work the Company has done to
identify partners that could provide or assist with the design and engineering work
necessary to take this distributed energy research beyond its current nature as high-
level, preliminary, and conceptual.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16 The Company has not
pursued further development of these options based on the preliminary estimates
exceeding the cost of the transmission option.
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 20
REQUEST FOR PRODUCTION NO. 17: The Company states, "ldaho Power
has an internal team focused on 1) seeking opportunities for funding sources for piloting
alternative technologies and 2) evaluating non-traditional approaches to resolve
distribution voltage and equipment overload issues. This team of engineers has been
evaluating potential applications of PV generation and baftery storage technology the
last few years." Exhibit 3 to Angell's Direct Testimony at 3 of 56. Please describe who
is on this team, the level of support they are receiving from the Company to evaluate
these technologies, and any funding opportunities pursued (include successfu! and
unsuccessfu I fund ing pursuits).
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: The team is presently
composed of an Engineering Leader, Engineering Project Leader, Principal Engineer,
and two Engineer 1s. Seventy percent of the team's time is focused on alternative
technology activities. Table 1 below lists the funding opportunities pursued with other
entities.
Table 1 Funding Opportunities Pursued
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 21
Opportunitv Title Lead Applicant Award Status
Smart Grid lnvestment
Grant Program
DE-FOA-0000058
ldaho Power Company's
Smart Grid: A customer-centric
approach to energy reliability,
efficiencv. and sustainabilitv
ldaho Power Awarded
Smart Grid lnvestment
Grant Program
DE-FOA-0000058
Western !nterconnection
Synchrophasor Program
WECC Awarded
Enhancing Short Term
Wind Energy
Forecasting
for lmproved Utility
Operations
DE-FOA-0000343
A Public-Private Wind Power
Forecast Demonstration
Project
WINDataNOW
Technologies,
LLC
Not Awarded
Clean Cities Community
Readiness and Planning
for Plug-in Electric
Vehicles and Charging
lnfrastructure
DE-FOA-0000451
ldaho's Treasure Valley:
Readiness and Planning for
Plug-in Electric Vehicles
Boise State
University,
Center for
Advanced
Energy Studies
Not Awarded
Clean Cities -
lmplementation
!nitiatives to Advance
Alternative Fuel Markets
DE-FOA-0000708
The ACT Project; Accelerating
Comm unity Transformations
with PEVs
Boise State
University,
Center for
Advanced
Enerqv Studies
Not Awarded
Pre-Commercial
Synchrophasor
Research and
Demonstration Grant
DE-FOA-0000970
Grid Operator's Monitoring and
Control Assistant
Peak RC Awarded
Oregon DOE Energy
Storage Demonstration
Pilot
330-1 186-15
(oDoE #15-013)
Jordan Valley Substation
Energy Storage Pilot
ldaho Power Evaluated but
not Submitted
lndustry Partnerships for
Cybersecurity of Energy
Delivery Systems
(CEDS) Research,
Development and
Demonstration for the
Energy Sector
DE-FOA-0001441
Detection, Classification and
mitigation of Cybersecurity
attacks on Synchrophasor
Systems
Texas A&M
University
Awarded
Enabling Extreme Real-
time Grid lntegration of
Solar Energy
(ENERGtSE)
DE-FOA-0001495
DERMs with Advanced
Prediction: High-Resolution
Forecasting and Stochastic
Feeder Analysis with Machine
Learnino
Sandia National
Laboratory
Pending
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB -22
REQUEST FOR PRODUCTION NO. 18: ln its Request For Production No. 16,
Commission Staff references that the Company stated its actual 1994-95 winter peak
load was 55.5 MW. In response to Tidwell's Request for Production No. 7, the
Company provided winter peak load information in Table 7.1, noting that the data
source (Pl historian) maintains data back to 2000. lf it is possible, please provide, in a
format similar to Table 7.1, the winter Coincident Peak for the North Valley during the
winters from 1994-95 through 1999-00, including as many of the following data sets as
are available: the tota! North Valley Peak (MW), the EKHN (MW) and KCHM (MW)
substation loads at the time of the peak, and the date and time the peak was
experienced.
Even if the data from the 1990s is limited in availability, please provide the full
Table 7.1 list of data for the Winter 2016-17.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: The Company does
not maintain coincident peak data before the year 2000. Please refer to Table 18.1
below for the date and time of the coincident North Valley peak demand for Winter
2016-17.
Table 18.1
Coincident Peak of North Valley
Year North Valley Peak (MW)EKHN (MW)KCHM (MW)Date and Time
Winter 2016-17 55.8 '1 1.9 43.9 12131115 6:10 PM
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 23
REQUEST FOR PRODUCTION NO. 19:
(a) !t states on Page i of the Engineering Data Management, lnc.'s December
1993 report to ldaho Power titled, "Structural Reliability and Risk Assessment of the
Wood River - Ketchum 138kV line #433": "The line was originally built in 1962 and was
initially operated at 46kV." Engineering Data Management, lnc. reports further
reference the line as having experienced a total of three minutes of outage over a
period of thirteen or fourteen years. When was the line first operated at 138kV?
(b) ln response to Tidwell's Request for Production No. 13, the Company
provided a table listing eleven outages on the Wood River-Ketchum line from "1995 to
present" caused by vandalism, inclement weather, wood decay, woodpecker damage,
avalanche, and/or micro-burst wind events. Please provide, in a format similar to the
table provided in response to that request, a list of all recorded outages on the Wood
River-Ketchum 138kV line 433 caused by vandalism, inclement weather, wood decay,
woodpecker damage, avalanche, and/or micro-burst wind events or maintenance of any
portion of the line between the WDRI and KCHM substations for the period beginning
when the line was first operated at 138kV through 1995. If any of these recorded
outages were the result of outages on a line or lines supplying power to the WDRI
substation please so indicate.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19:
(a) The line was first operated at 138 kV in 1970, based on the Company's
plant account records for Ketchum substation having 1970 vintage year entries for 138
kV equipment.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB -24
(b) The Company has not maintained outage records before 1995 on the
Wood River-Ketchum 138 kV line 443.
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 FIRST
PRODUCTION REOUEST OF IDAHO SIERRA CLUB - 25
REQUEST FOR PRODUCTION NO. 20: On page 22 ol Dave Angell's Direct
Testimony, Mr. Angell states, "Replacing the other 35 structures while the line is
energized would require much larger construction equipment pads that produce
significant environmental and aesthetic impacts, particularly on hillsides." Please
describe how these environmental and aesthetic impacts would compare to the impacts
of the Company's proposal for a redundant line.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: The existing
transmission line runs mostly in the hills between Hailey and Ketchum. Most of the
original access roads and equipment work pads have gradually eroded and vegetation
has grown over them. These roads and equipment work pads would all need to be
opened up and rebuilt to get access to the line and to work on the line. The equipment
work pads are needed so that the equipment has a flat area to set up and work on the
line. These work pads need to be larger when working on an energized transmission
line because there is more equipment required to perform the work. The proposed
redundant line runs mostly along existing roads and is on level ground, so there is
already access to the line. Work pads will not need to be constructed where there is
level ground to set up the equipment.
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 FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 26
REQUEST FOR PRODUCTION NO. 21: !n David Angell's Direct Testimony, he
states that "cities of Ketchum and Sun Valley prefer new electrical facilities be located
underground" and that "ldaho Power representatives have been advised that new
overhead lines would not be allowed in Ketchum and Sun Vallev." Angell at 24-25
(emphases added). In Michael Youngblood's Direct Testimony, he references the
ordinances in Ketchum and Sun Valley "requirinq new electrica! facilities to be located
underground." Youngblood at 22-23 (emphasis added). Does Idaho Power consider
the undergrounding of new lines in Ketchum and/or Sun Valley to be required or merely
preferred?
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: The undergrounding
of new power lines is both preferred and required by Ketchum and/or Sun Valley, as
well as by Blaine County. All three jurisdictions require all electric utilities, including
lines, associated with new subdivision development to be located underground. The
Comprehensive Plans of Blaine County, Ketchum, and Sun Valley all make various
references to placing and relocating utility power lines underground. ldaho Power must
obtain the required permits for the construction of lines from these entities and, as
stated in testimony, the Company has been advised that new overhead lines would not
be allowed by those entities in Ketchum and Sun Valley. Idaho Power's conditional use
permit application with Blaine County was denied, and the Company is currently in the
process of appealing such denial to the County Commissioners.
Additionally, ldaho Power's substantial work engaging the public, residents, and
leadership in the Wood River Valley, including the extensive work with the Community
Advisory Committees that developed and refined the Wood River Valley Electrica! Plan,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB -27
all clearly expressed the communities' preference and requirement that a new
transmission line be located either fully or partially underground.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
DATED at Boise, ldaho, this 27th day of Aprit2017.a*"2ilru
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 28
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 27th day of April 2017 ! served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF IDAHO SIERRA CLUB upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Camille Christen
Deputy Attorneys General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, 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
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
camille.christen@puc. idaho.qov
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_Overnight Mai!
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mai!_FAXX Email [e-mail]
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_Overnight Mail_FAXX Email michae![e-mail]
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_FAXxEmail [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 29
Kiki Leslie A. Tidwell
300 Let'er Buck Road
Hailey, ldaho 83333
Rolling Rock Properties, LLC, and
Rolling Rock Properties #2, LLC
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th 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 Va!!ey, ldaho 83353
Rolling Rock Properties #2, LLG
Rock Rolling Properties #2, LLC
c/o John Dondero
P.O. Box 739
Sun Valley, ldaho 83353
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
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_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mai!
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_FAX
Email
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Email
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City of Ketchum
Matthew A. Johnson
Wm. F. Gigray, lll
WHITE PETERSON GIGRAY
& NICHOLS, P.A.
5700 East Franklin Road, Suite 200
Nampa, ldaho 83687
lndividual
Laura Midgley
231 Valley Club Drive
Hailey, ldaho 83333
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 30
Gomcox, 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 IDAHO SIERRA CLUB - 31
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, Legal
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO, IPC.E.16.28
IDAHO POWER COMPANY
RESPONSE TO IDAHO SIERRA CLUB'S
REQUEST FOR PRODUCTION NO. 1
Wood River - Ketchum 138kV Line 433: Rebuild Options for Existins Transmission Line
Three construction scenarios have been identified that would allow the existing Wood River - Ketchum
138kV transmission line to be rebuilt. Preliminary costs of these three options have been developed and
are shown below, along with assumptions that were made for each scenario. The three scenarios are
listed in order of cost, from least to most.
Option 1- BASE: This option involves the replacement all of the existing wood, H-frame structures on
the existing H-frame line with similar, steel H-frame structures along the current alignment, in
approximately the same locations. The entire 12.5 mile route would be re-conductored with 397.5 ACSR
lbis conductor. This option assumes that the existing line can be taken out of service for long periods (6
months May - October) and that the existing load at Ketchum and Elkhorn substations will be supplied
from a separate source. This separate source is presumed to be either a second 138kV source from
Wood River to Ketchum substation or a 138kV source from Wood River to a new distribution station
located south of the Wood River Medical Center. The estimate for this option assumes the use of
existing right-of-way with no new acquisition necessary. This estimate does not include any new access
road work, landscaping repair or traffic control. lt does include the cost for removal and disposal of
existing structu res and conductor.
Estimated Cost: $5.2 million (includes 15% general overhead and 8o/o AFUDC)
Option 2 - Shoo-fly: This option involves the replacement all of the existing wood, H-frame structures
on the existing H-frame line with similar, steel H-frame structures along the current alignment, in
approximately the same locations. The entire 12.6 mile route would be re-conductored with 397.5 ACSR
lbis conductor. This option assumes that the existing line can be taken out of service for long periods (5
months from May - October) and that the existing load at Ketchum and Elkhorn substations will be
supplied from a temporary shoo-fly line to be built from Wood River Sub to Ketchum Sub along a route
that roughly follows Highway 75. The temporary shoo-fly will only be in place while the existing line is
rebuilt and will be removed after the rebuild is complete. The shoo-fly would consist of single, wood-
pole structures with horizontal post insulators and would have 300 foot typical span lengths. After, the
existing line is rebuilt, the shoo-fly would removed and the majority of materials (poles and insulators)
would be salvaged. The conductor used for the shoo-fly would be scrapped. The estimate for the
rebuild of the existing line assumes the use of existing right-of-way with only a small amount of
temporary ROW acquisition necessary for the shoo-fly. This estimate does not include any new access
road work or landscaping repair. lt does include traffic control for the shoo-fly work. lt does include the
cost for removal and disposal of existing structures and conductor on the existing WDRI-KCHM 138kV
line.
Estimated Cost: $9.4 million (includes 15% generaloverhead andS% AFUDC)
Option 3 - Hot Work & Outages: This option involves the replacement all of the existing wood, H-frame
structures on the existing H-frame line with similar, steel H-frame structures along the current
alignment, in approximately the same locations. This option assumes that the existing line cannot be
taken out of service for long periods and must remain in service as much as possible to serve the load at
Ketchum and Elkhorn Substations. lt is not feasible to replace the energized conductors without an
extended outage, so the existing 4/0 ACSR conductor on the entire 12.5 mile route would remain in
place and would be transferred to the new structures under this option. Since no long-term line outage
will be available under this option, as much structure replacement work as possible will be done with
the line energized. ln order to replace the H-frame structures with the line energized, unrestricted, level
access to both sides of the structure must be available (approximately 50 feet of clear space on each
side). This clear space is necessary to position large cranes and bucket trucks on each side of the
existing structure to lift, spread and support the existing energized-phase conductors away from the
immediate vicinity of the structure using insulated equipment. lf either or both sides of the structure
are restricted by residential development, vegetation or steep terrain, then the structure could not
safely be replaced using "energized methods" and an outage would be necessary. Each of the
structures was evaluated using aerial photos and topographic maps to determine if adequate access was
available. lt was determined that approximately 34% of the structures (35-40 total) were candidates for
being changed out with the line energized. Approximately 50% of the structures (50-50 total) on the
existing line would require outages to replace the structures and about L6% (2O structures) of the
structures in the vicinity of The Valley Club are a newer vintage and would not need to be replaced. ln
order to replace the 50 to 50 structures that require outages, it is preliminarily estimated that it would
require 20-25 individual 8-hour outages, if two crews were assigned the work. lt follows, that this
number could be reduced to 10 to 13 individual 8-hour outages if four crews were mobilized to work the
outages. Given the large number of customers and businesses that would be adversely affected by this
number of outages, this option would have much larger societal impacts than Option L or 2. Option 3
also has much greater environmental impacts because of the large, level equipment pads that must be
built around the structures that would be replaced "hot". Option 3 also has inherent worker safety
issues that result from working on energized conductors. This increased safety risk is impossible to
quantify. Also, Option 3 does not replace the transmission conductor, so it doesn't resolve allof the
issues of reliability and aging infrastructure that are the goalof this project. Because Option 3 comes at
a higher construction, societal, safety and environment cost than either Option l or 2, and because it
produces less long-term benefit, it has been determined that this option is not practical or feasible and
will not be pursued further.
Estimated Cost: Not determined because of difficulty quantifying construction, societal, safety and
environmental costs.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC.E.16.28
IDAHO POWER GOMPANY
RESPONSE TO IDAHO SIERRA CLUB'S
REQUEST FOR PRODUCTION NO.6
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