20170501Rock Rolling 1-16 to IPC.pdf

Gregory M. Adams (ISB No. 7454)
Peter J. Richardson (ISB No. 3195)
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise,Idatro 83702
Telephone : [phone]
Fax: [phone]
[e-mail]
peter@richardsonadams. com
Attomeys for Rock Rolling Properties, LLC
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-16-28
IN THE MATTER OF THE APPLICATION OF
TDAHO POWER COMPANY FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY TO CONSTRUCT SYSTEM
IMPROVEMENTS FOR WOOD RTVER
VALLEY CUSTOMERS
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FIRST SET OF PRODUCTION
REQUESTS OF ROCK ROLLING
PROPERTIES, LLC TO IDAHO
POWER COMPANY
Rock Rolling Properties, LLC hereby requests that Idaho Power Company ("Idatro
Power" or the "Company") provide responses to the following requests for production under
Rule 225 of the Rules of Procedure of the ldaho Public Utilities Commission (the "IPUC" or
"Commission").
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplementary responses additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide one physical copy and electronic-mail copies of the responses to Gregory
M. Adams at the addresses noted above.
FIRST SET OF PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC TO
IDAHO POWER COMPANY
rPC-E-16-28
PAGE 1
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at an evidentiary
hearing.
REQUEST NO. 1: Reference the Oregon Public Utility Commission's Seven-Year Electric
Service Reliability Statistics Report, available at http://www.puc.state.or.us/safety/Seven-
Year%20Elec%20Service%20Reliability%20Study%20May%2020 I 6.pdf. Provide the same
information displayed in the report for the Company's circuits (in the same format as the report,
i.e. averaged across those circuits) located in tdatro for each of the last 30 years for which data is
available, including the following reliability indices:
a. SAIFI (with Major Events excluded)
b. SAIFI (with Major Events included)
c. SAIDI (with Major Events excluded)
d. SAIDI (with Major Events included)
e. MAIFIe (with Major Events excluded)
f. CAIDI (with Major Events excluded)
REQUEST NO.2: Reference The Oregon Public Utility Commission's Seven-Year Electric
Service Reliability Statistics Report, available at http://www.puc.state.or.us/safety/Seven-
Year%20Elec%20Service%20Reliability%20Study%20May%202016.pdf. For the North Valley
circuit(s) (the circuits fed by the 138 kV Wood River-Ketchum line), please provide the
following indices as defined in the referenced report for each of the last 30 years for which data
is available:
FIRST SET OF PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC TO
IDAHO POWER COMPANY
IPC-E-16-28
PAGE 2
a. SAIFI (with Major Events excluded)
b. SAIFI (with Major Events included)
c. SAIDI (with Major Events excluded)
d. SAIDI (with Major Events included)
e. MAIFIe (with Major Events excluded)
f. CAIDI (with Major Events excluded)
REQUEST NO. 3: For each outage on a North Valley circuit identified in the response
Request No. 2, please explain: (i) whether Company confirmed that the location of the fault
causing the outage originated on the Wood-River-Ketchum 138 kV line, and if so (ii) how the
redundant transmission line proposed in the Application would have prevented the outage.
REQUEST NO. 4: Reference the Company's Response to StaffProduction Request No. 14.
Please provide a responsive explanation and supporting documents to the same question for the
Company's proposed redundant transmission line TPI (transition underground at Elkhorn Road).
In other words, provide the Company's estimates of condemnation costs of the Underground
Transmission line route from the Wood River substation to the Ketchum substation, including
identification and estimates of costs to condemn necessary property rights for all lots that must
be considered in such estimates.
REQUEST NO. 5: Please identify where in the Company's filing the costs identified in
response to Request No. 4 appear in the cost for the Underground Transmission line route TPl.
REQUEST NO. 6: Please explain precisely where the Company plans to route the overhead
transmission line along Hospital Drive if the Commission approves the proposed Underground
Transmission line route TPI (transition underground at Elkhorn Road). Specifically explain
FIRST SET OF PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC TO
IDAHO POWER COMPANY
IPC-E-16-28
PAGE 3
whether the Company believes the right of way on Hospital Drive is wide enough include the
transmission line as proposed in the Application without the need to condemn property or
otherwise obtain easements from property owners and provide all supporting documents and
studies on costs and safety issues to route line down Hospital Drive.
REQUEST NO. 7: Please explain whether Idaho Power has ever received a nuisance claim or
demand for payment, e.g. I.C. $ 52-101 et seq., from an abutting landowner to a transmission or
distribution line whose property is not crossed by the line. If so, please explain for each such
instance how the Company responded to such claims, and the liability and costs incuned by the
Company as a result of each such claim.
REQUEST NO. 8: Under the Underground Transmission line configurations (TP1, TP2, and
TP3), has Idaho Power considered any potential costs associated with liability to landowners
directly abutting the overhead portions of the transmission line but whose land the line does not
cross, such as nuisance claims under I.C. $ 52-l0l et seq.? If yes, please identifr provide all
documents and studies regarding the topic and identiff where such costs are included in the
Application for each line route option. If no, please explain why Idatro Power does not believe
this is a possible cost associated with the line route options.
REQUEST NO. 9: Reference R. Adelman,Ex. 7 at 2, please explain in detail the justification
for the estimates of "Right-of-Way" costs for the TPl, TP2, andTP3 options listed in the exhibit.
Please provide all work papers calculating these costs and all documents and studies supporting
the estimates in the work papers.
REQUEST NO. l0: Provide all documents describing steps that will need to be taken to ensure
that an overhead transmission line along Hospital Drive will not interfere with emergency
FIRST SET OF PRODUCTION REQUESTS OF ROCK ROLLTNG PROPERTIES, LLC TO
IDAHO POWER COMPANY
IPC-E-16-28
PAGE 4
helicopter operations by St. Luke's Hospital, including any additional lighting and location of the
line, and documents and sfudies demonstrating the Company can obtain necessary permits from
the Federal Aviation Administration.
REQUEST NO. 11: Reference the Company's Response to Staffs Production Request No.
l(c), stating that the overhead line route through Ketchum was abandoned because it would
require condemnation and residents and public officials were adamantly against having
transmission lines through downtown Ketchum. Please explain how these problems do not exist
along the overhead transmission sections of the Underground Transmission line routes TPl, TP2,
and TP3.
REQUEST NO. 12: Reference the Company's Response to StaffProduction Request No. l(e),
stating that the Company often restores power during outages tluough distribution switches, and
the Response to Tidwell Production Request No. 2(d), indicating there is one such tie switch fed
by the Hailey substation between the HALY-I5 circuit and the North Valley circuit.
a. Please explain why the existing infrastructure at the Hailey substation and
the existing distribution lines and corridor cannot be upgraded to provide a backup source
of power for the North Valley through this tie hitch.
b. With upgrades to the existing infrastructure as described in subpart a.,
what is the maximum load that ldaho Power could supply back-up power to the North
Valley through the referenced tie hitch?
c. Please provide all studies supporting the response in subparts a and b.
FIRST SET OF PRODUCTION REQUESTS OF ROCK ROLLTNG PROPERTIES, LLC TO
IDAHO POWER COMPANY
IPC-E-16-28
PAGE 5
REQUEST NO. 13: Please provide Idaho Power's peak electrical load for each month in the
past 30 years in the North Valley circuit. Please provide an estimate of the proportion of this
load that is space heating load and water heating load and the source of the estimate.
REQUEST NO. 14: Reference the Company's Response to StaffProduction Request No. 14,
stating that the Company estimates that condemnation or easement rights would cost
approximately 50% of the assessed value of the property (without improvements). What is the
basis for this estimate? Please provide all studies supporting this estimate would apply in resort
area such as the Wood River Valley.
REQUEST NO. 15: Reference the Company's Response to Sierra Club Production Request
No. 4, regarding the costs of the temporary shoe-fly line that would allow reconstruction of the
existing 138 kV Wood River-Ketchum line. Was this option presented to the Community
Advisory Committee (CAC)? Please provide all documents demonstrating this option was
presented to the CAC and the CAC's response that this option was unacceptable.
REQUEST NO. 16: Reference the Company's Response to Sierra Club Production Request
No. 1, Attachment, discussing the option of rebuilding the line while "hot."
a. Please identiff all transmission lines that Idaho Power has reconstructed
while hot in the past 30 years and the reason why the line was rebuilt while hot.
b. Was this option presented to the Community Advisory Committee (CACX
Please provide all documents demonstrating this option was presented to the CAC and
the CAC's response that this option was unacceptable.
DATED: May 1,2017
FIRST SET OF PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC TO
IDAHO POWER COMPANY
IPC-E-16-28
PAGE 6
RICHARDSON ADAMS, PLLC
By
M. Adams (ISB No. 7454)
FIRST SET OF PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC TO
IDAHO POWER COMPANIY
IPC-E-16-28
PAGE 7
CERTTFICATE OF SERVICE
I HEREBY CERTIFY that on the l"t day of May 2Ot7, I served a true and correct
copy of this First Set of Production Requests on the following via First Class
Mail and Electronic Mail:
Diane Hainan, Secretary
(Hand Delivery)
Idaho R.rblic Utilities Commission
472W Washington Street
Boise, ID 83702
Diane. holt@puc. idaho. gov
Tim Tatum
Idaho Power Company
l22l W Idaho Street
Boise ID 83702
t. [e-mail]
Kiki Leslie A. Tidwell
300 Let'er Buck Road
Hailey, Idaho 83333
[e-mail]
Zack Waterman
Director, Idaho Sierra Club
503 W Franklin Street
Boise, Idaho 83702
zack. waterman@sierraclub. org
Daphne Huang
IPUC
472 W Washington
Boise, ID 83702
daphne. huang@puc. idaho. gov
C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
Boise, ID 83702
tom. arkoosh@arkoosh. com
Donovan Walker
Idaho Power Company
l22l W Idaho Street
Boise, Idaho 83702
dwalke@idahopower. com
docket@idahopower. com
Peter Richardson
Richardson Adams, PLLC
515 N 27u" Street
Boise ID 83702
peten@richardsonadams. com
Laura Midgley
231 Valley Club Drive
Hailey, Idaho 83333
[e-mail]
Benjamin Otto
Idaho Conservation League
710 N Sixth Street
Boise, Idaho 83702
bott@idahoconservation. org
Camille Christen
IPUC
472 W Washington
Boise, lD 83702
camille. christen@puc. idaho. gov
Matthew A. Johnson
Wm. F. Gigray
White Peterson Gigray & Nichols, PA
5700 E. Franklin Rd., Suite 200
Nampa, tdaho 83687
mj ohnson@white pe terson. com
Michael Heckler
3606 N Prospect Way
Garden City, Idaho 83714
Michael. p. heckler@gmail. com
By:
M. Adams
Adams, PLLC