20170522IPC to Rock Rolling 1-16.pdf

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An IDACORP Company
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DONOVAN E. WALKER
Lead Counsel
dwal ker@idahopower. com
May 22,2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-16-28
Certificate of Public Convenience and Necessity for Wood River Valley
ldaho Power Company's Response to the First Set of Production Requests
of Rock Rolling Properties, LLC
Dear Ms. Hanian
Enclosed forfiling in the above matter please find an originaland three (3) copies of
ldaho Power Company's Response to the First Set of Production Requests of Rock Rolling
Properties, LLC.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to Rock Rolling Properties, LLC's production requests.
Very yours,
novan E ker
DEW:csb
Enclosures
'1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221\Nest 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 FIRST SET
OF PRODUCTION REQUESTS OF
ROCK ROLLING PROPERTIES,
LLC
COMES NOW, ldaho Power Company ("!daho Power" or "Comp?fly"), and in
response to the First Set of Production Requests of Rock Rolling Properties, LLC, to
ldaho Power Company dated May 1 ,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 1
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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%o20Elec%20Service%20Reliabilitv%20St
udvo/o20Mayo/o202016.odf. 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 ldaho 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. MAlFle (with Major Events excluded)
t. CAIDI (with Major Events excluded)
RESPONSE TO REQUEST NO. 1: PIease see the Exce! file provided on the
enclosed CD for data available for ldaho Power's Idaho jurisdiction. Beginning in 2008,
the Company migrated to a new outage management system ("OMS") and some of the
information requested before this time is unavailable.
The response to this Request is sponsored by Perry Van Patten, Transmission
and Distribution Engineering and Reliability Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 2
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/safetv/Seven-Year%20Elec%20Service%20Reliabilitv%20St
udv%20M 0206.odf. For the North Va lley 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:
a. SAIF! (with Major Events excluded)
b. SAIFI (with Major Events included)
c. SAIDI (with Major Events excluded)
d. SAIDI (with Major Events included)
e. MAlFle (with Major Events excluded)
f . CAIDI (with Major Events excluded)
RESPONSE TO REQUEST NO. 2: Please see the Excel file provided on the
enclosed CD. Beginning in 2008, the Company migrated to a new OMS and some of
the information requested before this time is unavailable. The Company defines the
geographic areas for determining Major Event Days at the state level only. Therefore,
no data is available specific to the Wood River Valley (i.e., North Valley) regarding
Major Event Days. Hence, no "Major Events excluded" is calculated for subparts a, c, e,
and f above. The data provided for subparts b and d above is applicable for those
circuits fed by the 138 kilovolt ("kV') Wood River-Ketchum line (i.e., KCHM-O11, KCHM-
012, KCHM-o13, KCHM-014, KCHM-o15, KCHM-o16, KCHM-o17, KCHM-o18, EKHN-
011, and EKHN-012).
The response to this Request is sponsored by Perry Van Patten, Transmission
and Distribution Engineering and Reliability Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 3
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
!ine, and if so (ii) how the redundant transmission line proposed in the Application would
have prevented the outage.
RESPONSE TO REQUEST NO. 3: Please see the attachment provided with the
Company's response to Rock Rolling Properties, LLC's ("Rock Rolling") Production
Request No. 2. Column H of the Excel file identifies those outages on the Wood River
Valley (i.e., North Valley) circuits that were caused by lack of the WDRI-KCHM 138 kV
transmission line. The "Transmission Line Outages Notes" section describes the date
of the outage and determined cause of the transmission line outage. The redundant
line allows for parallel paths for providing power to the Wood River Valley. Because the
outage on the Wood River-Ketchum 138 kV line on August 12, 2014, was weather
related, that same weather event could have also impacted a redundant line. The other
five outages noted likely would not have occurred had a redundant line been present.
The response to this Request is sponsored by Perry Van Patten, Transmission
and Distribution Engineering and Reliability Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 4
REQUEST NO. 4: Reference the Com pany's Response to Staff Production
Request No. 14. Please provide a responsive explanation and supporting documents to
the same question for the Company's proposed redundant transmission line TP1
(transition underground at Elkhorn Road). ln 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.
RESPONSE TO REQUEST NO. 4: ldaho Power attempts to avoid
condemnation when designing transmission lines by taking part in negotiated
resolutions to the extent possible. For the proposed redundant transmission line TP1
(transition underground at Elkhorn Road), ldaho Power does not anticipate
condemnation. The proposed transmission line route wil! replace an existing distribution
line in the road right-of-way for most of the route from the Wood River substation to the
intersection of Hospital Drive and State Highway 75. Continuing north, ldaho Power
plans to utilize the road right-of-way along Hospital Drive and either private easements
or road right-of-way for the remainder of the route to TP1. ldaho Power has had
preliminary discussions with landowners where private easements may be required, and
ldaho Power believes the easements can be acquired.
The response to this Request is sponsored by Ryan N. Adelman, Transmission
and Distribution Projects Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 5
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 TP1.
RESPONSE TO REQUEST NO. 5: Please see the Company's response to
Rock Rolling's Production Request No. 4. ldaho Power does not expect to incur costs
for condemnation for Underground Transmission line route TP1. However, ldaho Power
has included a range of costs associated with acquiring easements and right-of-way
that may be necessary to construct the line. These costs are included in Adelman
Direct, Exhibit No. 7, identified as right-of-way.
The response to this Request is sponsored by Ryan N. Adelman, Transmission
and Distribution Projects Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 6
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 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 othenuise obtain easements from property
owners and provide all supporting documents and studies on costs and safety issues to
route line down Hospital Drive.
RESPONSE TO REQUEST NO. 6:ldaho Power has not yet completed survey
and micro-siting of the final structure locations for the route. ldaho Power believes the
line will be constructed along the east side of Hospital Drive within the road right-of-way
as depicted on Angell Direct, Exhibit No. 6.
ldaho Power believes the right-of-way is of suitable width to construct the line.
Along portions of Hospital Drive, there appear to be some buildings with a zero setback
from the edge of the road right-of-way. However, the back of the sidewalk along
Hospital Drive is approximately 17 to 18 feet from the road right-of-way. This allows
suitable space to place the proposed transmission line along the back of the sidewalk
and still meet National Electric Safety Code ("NESC") clearance requirements to the
buildings. Please see the diagram (Attachment 1) and photo (Attachment 2) provided
on the enclosed CD.
ldaho Power has not performed a cost study specific to Hospital Drive, nor does
Idaho Power believe there are safety issues with constructing the line along Hospital
Drive.
The response to this Request is sponsored by Ryan N. Adelman, Transmission
and Distribution Projects Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 7
REQUEST NO. 7: Please explain whether ldaho Power has ever received a
nuisance claim or demand for payment, e.g. l.C. S 52-101 ef seg., 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 incurred by the Company as a result of each such
claim.
RESPONSE TO REQUEST NO. 7:ldaho Power is not aware of any such
claims.
The response to this Request is sponsored by Pat Harrington, Corporate
Secretary, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 8
REQUEST NO. 8: Under the Underground Transmission line configurations
(TP1, TP2, and TP3), has ldaho Powerconsidered any potentia! 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 !.C. S 52-101 et
seg.? lf yes, please identify provide all documents and studies regarding the topic and
identify where such costs are included in the Application for each line route option. lf
no, please explain why ldaho Power does not believe this is a possible cost associated
with the line route options.
RESPONSE TO REQUEST NO. 8: ldaho Power has not included any such
costs for the overhead transmission line segments of options TP1, TPz. or TP3. ldaho
Power does not believe that the adjacent property owners described in this Request
would have any valid claim for damages under ldaho law (whether based on nuisance
or othenruise) in connection with ldaho Power's installation of the transmission line
(which will be primarily located within the road right-of-way) under options TP1, TP2, or
TP3.
The response to this Request is sponsored by Pat Harrington, Corporate
Secretary, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 9
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 TP1, TPz, and TP3 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.
RESPONSE TO REQUEST NO. 9: Right-of-way acquisition costs can vary
substantially for a project; therefore, the costs were estimated as a range in the
referenced exhibit. Please see the attachment provided on the enclosed CD.
Right-of-way costs for TP1 , TP2, and TP3 were based on conceptual level designs and
the need to secure right-of-way from private property owners for underground cable
splice boxes, transition structure locations, and sections of the power line. Easement
footprints were estimated based on the area needed to place electrical equipment.
Land costs were estimated based on the assessed value, including an assumption of
the percentage of the value that would be necessary to acquire the right-of-way, ranging
from 50 percent to 100 percent.
For TP1, right-of-way was assumed to be needed for an overhead section of line
to access the transition structure, the transition structure location, and splicing vaults for
the underground line. For TP2, right-of-way was assumed to be needed for an
overhead section of line across the intersection of State Highway 75 and Hospital Drive
and splicing vaults for the underground line. For TP3, rightof-way was assumed to be
needed for an overhead section of line to access the transition structure, the transition
structure location, easements across private land for the underground cable to route the
line below the bike path crossing at the intersection of State Highway 75 and Hospital
Drive, and splicing vaults for the underground cable.
The response to this Request is sponsored by Ryan N. Adelman, Transmission
and Distribution Projects Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 1O
REQUEST NO. 10: 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 helicopter operations by St. Luke's Hospital, including any additional
lighting and location of the line, and documents and studies demonstrating the
Company can obtain necessary permits from the FederalAviation Administration.
RESPONSE TO REQUEST NO. 10: ldaho Power had verbal and e-mail
correspondence with the Federal Aviation Administration ("FA4") in June 2016 about
the potential power line route along the west side of State Highway 75 and along the
east side of Hospital Drive. The FAA reviewed with the helicopter operator and
informed ldaho Power that both the FAA and the operator did not see a problem with
the proposed power line. Please see Attachment 1 provided on the enclosed CD. St
Luke's Hospital and the helicopter operator verbally requested that marker lights be
installed on the top of the power poles where the line crosses Hospital Drive south of
the hospital, similar to the lights installed at Pole Line Road near the Twin Falls helipad.
These Iights would increase visibility and awareness of the poles and associated wire
locations at night. Additionally, St Luke's Wood River Medical Center wrote a letter to
the Blaine County Commissioners in support of the redundant line and of granting an
easement across a portion of its property in order to "make the project a reality." Please
see Attachment 2 provided on the enclosed CD.
The response to this Request is sponsored by Ryan N. Adelman, Transmission
and Distribution Projects Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 11
REQUEST NO. 11: Reference the Company's Response to Staffs Production
Request No. 1(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 TP1,TP2, and TP3.
RESPONSE TO REQUEST NO. 11: Refer to ldaho Power's responses to the
ldaho Public Utilities Commission Staff's ("Staff') Production Request Nos. 14 and 17.
The design and construction challenges working in a downtown environment are
substantially different than working along the more rural sections of the project. The
challenges discussed in ldaho Power's responses include that the City of Ketchum
allows for zero setback buildings in the Ketchum Downtown District. Existing buildings,
and any proposed buildings, are constructed with zero setbacks along front and side
roads within the downtown area. As a result, wires would need to be placed out over
the street, or easements would need to be acquired, to allow for required clearances
between these buildings and the energized line to meet the NESC. Other challenges in
a downtown district include sight distance considerations for structures at intersections
and structures being placed in sidewalks or out in the street.
For the portion of the overhead route located in Blaine County, ldaho Power
plans to follow an existing distribution line and replace it with a transmission line
primarily within the road right-of-way. Blaine County has established setbacks along
State Highway 75 and other major and minor roads as part of its code. This setback is
for buildings and other structures. The setbacks established by Blaine County where
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 12
the transmission line will be routed are greater than the clearance requirements as
required by the NESC. Therefore, ldaho Power does not have the same challenges
associated with clearance requirements for the overhead lines in the Blaine County
portion of the project.
The response to this Request is sponsored by Ryan N. Adelman, Transmission
and Distribution Projects Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 13
REQUEST NO. 12: Reference the Company's Response to Staff Production
Request No. 1(e), stating that the Company often restores power during outages
through 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-15 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.
RESPONSE TO REQUEST NO. 12:
a. The distribution circuit from the Hailey substation could be upgraded to
increase the backup service capacity for the single Elkhorn distribution circuit beyond
the existing 1.3 megawatts ("MW"); however, this stil! does not provide the required
redundant service requested with the Certificate of Public Convenience and Necessity
in this case.
b. At current loading levels and with a 6.5 mile replacement of the existing
distribution circuit, approximately 7 MW of capacity could be provided to the referenced
tie switch. However, the Elkhorn substation distribution circuit conductor and regulating
device would also require upgrades. All these upgrades would allow partial backup
service to the single Elkhorn substation distribution circuit. During this configuration,
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC. 14
there would be no backup supply to the second Elkhorn distribution circuit customers
and the customers served from the Ketchum substation.
c. No study has been conducted. The information provided is based on
knowledge of the existing circuits, the distance from the Hailey substation to the tie
switch, and the current loading on the Hailey 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 SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 15
REQUEST NO. 13: Please provide ldaho 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.
RESPONSE TO REQUEST NO. 13: The following table provides the requested
information on monthly peak data. The Company's data source (Pl historian) maintains
data back to 2000. The Company has not determined the percentage of load due to
space heating and water heating on the North Valley distribution circuits.
Coincident Peak of the North Valley
Year North Valley Peak (MW)Date and Time
September-00 20.8 9l2lOO 10:25 AM
October-00 27.0 1012710010:20 AM
November-00 43.8 11l28lOO 8:15 AM
December-00 51.6 12l28lOO 9:30 AM
Januarv-O1 52.5 11161018:30 AM
February-01 52.2 2181018:15 AM
March-O1 40.7 3111018:10 AM
April-01 24.9 4l3ll18:25 AM
Mav-01 19.9 5131017:20 AM
June-01 16.9 614101 10:40 AM
July-O1 16.4 715101 11:00 AM
Auqust-O1 20.1 81151019:10 AM
September-01 15.7 9171018:15 AM
October-01 27.3 101251018:20 AM
November-01 45.0 11128101 10:00 AM
December-01 51.2 121121018:25 AM
January-02 50.7 1130102 6:50 PM
February-02 45.3 214102 6:50 PM
March-02 43.7 313102 9:10 AM
April-02 28.0 4118102 7:40 AM
May-02 24.1 5l8lo2 7:30 AM
June-02 20.1 6111102 8:30 AM
July-02 20.3 71510210:15 AM
Auqust-02 20.9 819102 9:25 AM
September-02 21.9 9130102 8:30 AM
October-02 39.3 10131102 8:50 AM
November-02 40.7 11125102 8:10 AM
December-02 54.9 12124102 9:05 AM
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 16
January-03 45.0 1117103 8:15 AM
Februarv-03 43.4 2t6103 6:55 PM
March-03 39.0 311103 7:10 PM
April-03 31.0 417103 8:00 AM
Mav-O3 22.3 511103 7:35 AM
June-03 20.9 612410310:30 AM
July-03 21.4 7124103 11:20 AM
Auqust-03 20.9 8/8/03 9:40 AM
September-03 22.6 9/18/03 8:20 AM
October-03 34.9 10/31/03 7:50 AM
November-03 44.1 11125103 8:15 AM
December-03 54.9 12128103 5:45 PM
January-04 47.9 111104 5:55 PM
Februarv-04 46.1 2112104 8:25 PM
March-04 39.5 315104 8:05 AM
April-04 24.6 4120104 1 1:10 AM
Mav-04 21.9 5125104 8:10 AM
June-04 19.6 6130104 5:30 PM
July-04 22.8 71910410:10 AM
Auoust-04 21.7 8127104 9:05 AM
September-04 21.7 9121lO4 8:05 AM
October-04 32.0 10131104 7:45 AM
November-04 47.6 '11130104 8:20 AM
December-04 56.3 12123104 9:20 AM
January-O5 52.',|116105 9:10 AM
Februarv-05 47.6 2115105 8:35 PM
March-05 35.7 3118105 6:10 AM
April-05 32.3 411105 8:30 AM
Mav-05 24.9 5/10/05 9:40 AM
June-05 24.3 6/8/05 8:00 AM
July-05 22.9 7129105 5:20 PM
Auqust-05 24.4 8/8/05 10:30 AM
September-05 24.5 9112105 8:35 AM
October-05 32.9 10/31/05 7:25 AM
November-05 47.1 11t28105 8:50 AM
December-05 55.9 1218105 8:50 AM
January-06 52.4 '119106 9:10 AM
February-06 47.3 2120106 9:00 AM
March-06 44.6 3/10/06 8:05 AM
Aoril-06 32.5 412106 9:25 AM
May-06 23.8 5/3/06 7:35 AM
June-06 19.3 6/9/06 10:55 AM
July-06 23.7 711210612:30 PM
Auqust-06 22.4 8/31/06 10:05 AM
September-06 22.4 9/18/06 9:45 AM
October-06 35.6 1Ol31lOG 7:40 AM
November-06 51.6 11129106 8:25 AM
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 17
December-06 54.8 12129106 9:30 AM
January-O7 60.6 1113107 9:20 AM
Februarv-07 53.0 212107 8:25 AM
March-07 42.9 3l2l17 8:10 AM
April-07 30.9 413107 8:40 AM
May-07 18.9 511107 8:40 AM
June-07 22.8 616107 10:20 AM
July-07 23.6 7112107 10:10 AM
Auoust-O7 23.6 8128107 11:40 AM
September-07 23.3 9126107 9:05 AM
October-07 35.6 '10122107 8:05 AM
November-07 43.3 11130107 10:00 AM
December-07 63.8 12131107 6:45 PM
January-08 59.2 1122108 9:20 AM
Februarv-08 48.1 215108 8:40 AM
March-08 42.3 3/6/08 7:40 AM
April-08 41.7 411108 8:30 AM
Mav-08 28.3 512108 7:45 AM
June-08 23.8 6111108 9:00 AM
July-08 23.6 71910811:05 AM
Auoust-08 24.5 8/8/08 1 1:00 AM
September-08 24.7 912108 9:05 AM
October-08 34.3 10123108 8:45 AM
November-08 41.3 11124108 9:00 AM
December-08 59.2 1212410810:00 AM
January-09 57.9 1l4l1g 9:20 AM
February-09 47.7 2115109 7:05 PM
March-09 46.1 3111109 9:00 AM
April-09 34.8 411log 8:20 AM
May-09 25.5 511109 8:05 AM
June-09 21.5 6t22109 8:20 AM
Julv-09 23.0 7124109 5:20 PM
Auqust-O9 23.4 81710911:15 AM
September-09 21.8 9/8/09 8:35 AM
October-09 37.9 10129109 8:40 AM
November-09 44.7 11123109 8:15 AM
December-09 57.9 1213110910:30 AM
Januarv-10 51.9 118110 8:40 AM
February-10 45.0 2/10fi0 6:15 AM
March-10 39.4 3111110 8:00 AM
April-10 36.3 412110 8:30 AM
Mav-10 26.0 517110 7:20 AM
June-1 0 22.0 6118110 9:10 AM
Julv-10 23.1 712611010:05 AM
Auoust-10 23.5 8110110 9:50 AM
September-10 23.6 916110 9:50 AM
October-10 36.3 101271108:15AM
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 18
November-10 50.1 11125110 8:35 AM
December-10 62.0 12131110 9:50 AM
January-11 60.5 1/1/11 10:05 AM
Februarv-1 1 50.7 2121116:10 AM
March-11 40.1 3181118:00 AM
April-11 33.8 4141118:40 AM
Mav-11 24.6 5121117:25 AM
June-1 1 22.5 6131118:10 AM
July-11 23.0 7161115:05 PM
Auoust-11 22.7 8112111 9:50 AM
September-11 38.5 9127111 6:00 AM
October-11 35.7 10128111 8:55 AM
November-11 45.1 11126111 8:30 AM
December-11 55.5 12123111 9:25 AM
January-12 54.4 1117112 9:05 AM
February-12 45.2 2120112 9:40 AM
March-12 42.6 312112 8:25 AM
Aprill2 33.5 412112 8:20 AM
Mav-12 24.2 512511210:00 AM
June-1 2 21.7 619112 4:00 PM
Julv-12 23.9 715112 '10:15 AM
Auqust-12 23.9 81611211:35 AM
September-12 21.5 913112 9:30 AM
October-12 37.8 10124112 8:40 AM
November-12 41.4 11127112 8:50 AM
December-12 56.6 12130112 6:35 PM
January-13 59.5 1114113 8:55 AM
Februarv-13 43.1 2111113 9:10 AM
March-13 39.9 315113 7:55 AM
April-13 29.4 4115113 7:35 AM
May-13 24.5 511113 7:30 AM
June-1 3 21.6 6125113 11:00 AM
July-13 23.8 711113 2:30 PM
Auqust-13 22.3 8181131 1:00 AM
September-13 24.4 9127113 9:05 AM
October-13 32.6 10130113 9:05 AM
November-13 40.5 11122113 8:15 AM
December-13 54.0 12129113 9:30 AM
January-14 51.5 114114 9:10 AM
February-14 47.4 216114 8:55 AM
March-14 36.2 3112114 8:35 AM
April-'14 31.6 413114 8:25 AM
May-14 21.9 518114 8:20 AM
June-14 24.0 6l'18114 9:40 AM
Julv-14 23.3 7114114 2:25 PM
Auqust-14 32.8 8112114 8:00 PM
September-14 21.0 91111410:05 AM
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 19
October-14 32.0 10128114 8:55 AM
November-14 27.4 11120114 2:40 PM
December-14 59.7 12131114 6:20 PM
January-15 57.7 112115 9:50 AM
Februarv-1 5 40.1 2123115 8:05 AM
March-15 36.9 314115 8:35 AM
April-15 29.3 413115 8:05 AM
Mav-15 20.9 511511510:40 AM
June-1 5 23.4 6130115 1:15 PM
July-15 24.8 713115 5:30 PM
Auqust-15 22.6 8113115 4:15 PM
September-15 22.1 917115 9:25 AM
October-15 33.9 101141157,25 AM
November-15 47.4 11130115 8:30 AM
December-15 60.8 12131115 6:10 PM
January-16 55.0 111116 6:20 PM
Februarv-16 47.0 213116 9:05 AM
March-16 37.0 3118116 8:35 AM
April-16 28.8 411l'16 8:05 AM
Mav-'16 21.4 5120116 11:05 AM
June-16 21.7 6/30/16 1:10 PM
July-16 23.3 7129116 4:55 PM
Auoust-16 23.0 812116 5:30 PM
Seotember-16 22.3 9/5/16 9:45 AM
October-16 31.8 10119116 9:40 AM
November-16 39.5 11130116 8:40 AM
December-16 55.8 12122116 9:00 AM
January-17 52.5 1l2l'17 5:30 PM
February-17 44.2 2127117 9:05 AM
March-17 41.7 311117 8:20 AM
April-17 32.3 414117 8:10 AM
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 FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 20
REQUEST NO. 14: Reference the Company's Response to Staff Production
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.
RESPONSE TO REQUEST NO. 14:ldaho Power's Response to Staffs
Production Request No. 14 referenced in this Request states in relevant part: "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."
Idaho Power does not have a formal policy of paying 50 percent of market land
value for power line easements. This is a general approach the Company fo!!ows, but
easement valuations may vary from case to case (typically between 25 percent to 100
percent land value). One key consideration for easement valuations relates to the
impact the power line installation will have on the current land use. In some cases,
such as agricultural land use, the power line poles can be located to minimize the
impact on the farming operations. ln other mses, such as locating the line in the middle
of a residential lot, the restrictions on the property use wi!! be greater and the easement
percentage utilized will also be greater.
Land values in the Wood River Valley tend to be quite high relative to other parts
of ldaho Power's service area. However, this does not necessarily mean the easement
percentage applied to that land value will be higher than norma!. While the overall
easement price will be higher due to the higher underlying land value, the easement
percentage (e.9., 50 percent) may be similar to that used for less expensive land.
The response to this Request is sponsored by Pat Harrington, Corporate
Secretary, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 21
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.
RESPONSE TO REQUEST NO. 15: No, this option was not presented to the
CAC as it is inconsistent with the its reliability goal found in Appendix C, page 6 of the
Wood River Electrical Plan. lt states, "Provide redundant transmission facilities
throughout the Wood River Valley."
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 SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 22
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 identify all transmission lines that ldaho 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 (CAC)?
Please provide all documents demonstrating this option was presented to the CAC and
the CAC's response that this option was unacceptable.
RESPONSE TO REQUEST NO. 16:
a. ldaho Power has not reconstructed any full-length transmission lines while
hot in the past 30 years. The conductor itself cannot be replaced while the line is
energized. ldaho Power has replaced some individual structures while the transmission
line was hot and transferred the existing conductor to the new structures. This is only
performed when the line can be worked on safely.
b. No, this option was not presented to the CAC as it is inconsistent with its
reliability goal found on Appendix C, page 6 of the Wood River Electrical Plan. lt states,
"Provide redundant transmission facilities throughout the Wood River Valley."
The response to this Request is sponsored by Ryan N. Adelman, Transmission
and Distribution Projects Manager, Idaho Power Company, and Dave Angell,
Transmission and Distribution Planning Manager, ldaho Power Company.
DATED at Boise, ldaho, this 22nd day of May 2017.
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of May 2017 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC, 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
Idaho Gonservation League
Benjamin J. Otto
Idaho 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, Idaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Kiki Leslie A. Tidwe!!
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
cam i I le. ch risten@puc. idaho. qov
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Emai! [e-mail]
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_Overnight Mail
_FAXX Email [e-mail]
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_Overnight Mail
_FAXX Email [e-mail]
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_Overnight Mail
_FAXX Email [e-mail]
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_Overnight Mail
_FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 24
Kiki Leslie A. Tidwell
300 Let'er Buck Road
Hailey, ldaho 83333
Rock Rolling Properties, LLC, and
Rock Rolling Properties #2, LLG
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Rock Rolling Properties, LLC
Rock Rolling Properties, LLC
c/o Kris Dondero
P.O. Box 739
Sun Valley, ldaho 83353
Rock Rolling Properties #2, LLC
Rock Rolling Properties #2, LLC
c/o John Dondero
P.O. Box 739
Sun Valley, ldaho 83353
Gity 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
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_FAXxEmail ktin cox.net
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FAXX Email nadams.com
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_FAX
Email
_Hand DeliveredX U.S. Mail
_Overnight Mail_FAX
Email
_Hand DeliveredX U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mai!
_Overnight Mail
_FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 25
GoxGom, LLG
C. Tom Arkoosh
ARKOOSH tAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
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Christa Bearry, Legal nt
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 26