20170817Hearing Transcript Vol II.pdf

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CSB REPORTING
Certifted Shorthand Reporters
Post Office Box9774
Boise,Idaho 83707
[e-mail]
Ph: 208-890-5198 Fax: [phone]
Reporter:
Constance Bucy,
CSR
BEFORE THE IDAHO PUBLIC UTIL]TIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
CERTIEICATE OE PUBL]C CONVEN]ENCE
AND NECESSITY TO CONSTRUCT
SYSTEM IMPROVEMENTS FOR WOOD
RIVER VALLEY CUSTOMERS
CASE NO. IPC-E-16-28
BEFORE
COMMISSIONER ERIC ANDERSON (Presiding)
COMMISSIONER KRISTINE RAPER
COMMISS]ONER PAUL KJELLANDER
PLACE:Commission Hearj-ng Room
412 West Washington Avenue
Boise, Idaho
DATE:August 8, 20L7
VOLUME II Pages 96 370
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CSB REPORTING
(208 ) 890-s198
APPEARANCES
For the Staff:Daphne Huang, Esq.
Deputy Attorney General
412 West Washington
Boise, Idaho 83720-0074
For Idaho Power Company:Donovan E. Iilalker, Esq.Idaho Power Company
Post Office Box 10
Boise, Idaho 83707-0070
For Lesl-ie A. Tidwef l-:R]CHARDSON ADAMS, PLLC
by Peter J. Richardson, Esq.
Post Office Box 7278
Boise, Idaho 83102
For Rock Rolling
Properties, LLC:
R]CHARDSON ADAMS, PLLCby Gregory M. Adams, Esq.
Post Office Box 1278Boise, Idaho 83102
For the Sierra CIub:KELSEY JAE NUNEZ LLC
by Kelsey ilae Nunez, Esg.
920 North Clover DriveBoise, Idaho 83703
Eor City of Ketchum:WHTTE PETERSON GIGRAY
& NICHOLS, PA
by t'Iatthew A. ilohnson
5700 E. Franklin Road
Nampa, Idaho 83687
For Coxcom, LLC:ARKOOSH LAW OFEICES
by C. Tom Arkoosh, Esq.
Post Office Box 2900
Bolse, Idaho 83701
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APPEARANCES
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CSB REPORT]NG(208) 890-s198
INDEX
WITNESS EXAMINATION BY PAGE
Michael- Youngblood(Idaho Power Company)
Mr. WaIker (Direct)
Prefil-ed Dlrect Testimony
Mr. Adams (Cross )Mr. Richardson (Cross)
Ms. Nunez (Cross)
Commissioner Kj ellander
Commissioner Raper
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103t4r
156
187
190
792
David Ange1l(Idaho Power Company)
Mr. Wal-ker (Dlrect)
Prefil-ed Direct TestimonyPrefiled Rebuttal TestimonyPrefiled Surrebuttal- Test.
Mr. Adams (Cross )Mr. Richardson (Cross)
Mr. Arkoosh (Cross)
Ms. Huang (Cross)
Commissioner Kj ellander
Commissioner Raper
Commissioner Anderson
796
799
239
266
300
320
352
3s6
362
36s
368
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CSB REPORTING
W1l-der, Idaho 83616
EXHIBITS
NUMBER DESCRIPT]ON PAGE
FOR ]DAHO POWER COMPANY:
1 Letter from Donovan WaIker
dated 5/79/16, with attachments
Premarked
2
3
Wood River El-ectrical- Pl-an Premarked
Wood River Va1ley Transmission PremarkedLine Update
4 Hailey to Ketchum Overhead
Transmission Line Optlon
Premarked
5 Hailey to Ketchum Underground
Transmission Line Option
Premarked
6 Hailey to Ketchum Primary OHDistributlon Line Option
Premarked
B Idaho Power Confidential Exhibit Premarked
FOR THE STAFE
113 Request & Response for
Production No. 4
Identified 359
EOR LESLIE T]DWELL
207 Photograph showing a fire in
the background
Identified 796
EOR COXCOM, LLC:
701 Pole Height Dj-agram Identified
Admitted
3s4
368
102 Pole Height Diagram Ident i fied
Admitted
354
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EXHIB]TS
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CSB REPORTING
Wil-der, Idaho 83616
EXHIBITS (Continued)
NUMBER DESCRIPTION PAGE
FOR ROCK ROLLING PROPERTIES LLC:
801 Blaine County P&.2,
Eacts, Conclusions
Decision
Findings ofof Law &
Marked
Admitted
145
145
802 Request & Response for
Production No. 4
Marked
Admitted
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311
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CSB REPORTING
(208 ) 890-5198
BOISE, IDAHO, TUESDAY,AUGUST 8, 2011, 9:30 A. M
COMMISSIONER ANDERSON: Good morning.
It's August 8th, 2011, and this is the time and place set
for a technical hearing in Case No. IPC-E-16-28, further
identified as in the matter of Idaho Power Company's
application for a certificate of public convenience and
necessity to construct system improvements to secure
adequate and reliable servj-ce to customers in the Wood
River Va11ey. This hearing is now in order and it is
taking place to consider that application for a
certificate of public convenience and necessity filed on
November 72thl, 2076.
My name is Eric Anderson, and I'l-l- be
Chairing this committee, this proceedi-ng, and to my right
is Commissioner Kristine Raper and to my left is
Commissioner Paul Kjellander. We comprise the Commission
and we wil-I ul-timately determj-ne the outcome of these
proceedings.
appearances of
ahead and let's
around the room
Welcome.
We'l-l- begin this morning by taking the
parties and so I think that we should go
begi-n with the Applicant and then go
and have each party introduce themsel-ves.t 25
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MR. WALKER: Thank you, Mr. Chairman.
Donovan Wa1ker on behalf of Idaho Power Company.
MR. RICHARDSON: Mr. Chairman, Peter
Richardson with the firm Richardson Adams here on behal-f
of Ms. Tidwel-l who is sitting to my left.
COMMISSIONER ANDERSON: Welcome.
MR. ADAMS: Greg Adams, also with the firm
Richardson Adams,
Properties, LLC,
MR
here on behalf of the Rock Rolling
and Rock Rolling Properties #2, LLC
Communicatlons, is
ARKOOSH: Tom Arkoosh appearing for
and Guy Cherp, vice president of Cox
sitting behind me.
MS. NUNEZ: Kelsey Nunez representing the
Idaho Sierra Cl-ub, and I have Mike Heckler and Zack
Waterman here with me.
MR WATERMAN: Zack Waterman, chapter
director for the Sierra CIub.
Cox Communications
MR. JOHNSON: Matthew
City
Nina
of Ketchum, and
Ketchum,
Mq HUANG: Daphne Huang representing
l-ef t is Dr. MikeCommission Staff and seated to my
Morrison.
COMMISSIONER ANDERSON: Wel-come. Are
there any parties that we've missed for the purpose of
Johnson, city
f have with me theattorney
Mayor of
for the
Jonas.
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CSB REPORTING
(208 ) 890-s198
identification in the record?
preliminary matters that need
Commission?
MS. HUANG: Mr.
have do we
If not, are there any
to come before the
Chair, I don't
have Laura Midgley present? I
the record Laura Midgley is an
and I don't bel-ieve that she's present at
know if we
guess we'11
intervenorjust note for
in this case
the proceedings today.
COMMISSIONER ANDERSON: Thank you for that
note. I appreciate that. Preliminary matters?
MR. RICHARDSON: Mr. Chaj-rman, Peter
Richardson on behalf of Ms. Tidwel-l-. The intervenors
have conferred
prosecution of
and think it would be most efficient for
the
go
Ms
first on cross
hearing this morning
order, followed by me
to have Mr. Adams
and followed by
di-scussed thisNunez of the Sierra Cl-ub, and we've
with counsel- for Idaho Power and they expressed no
opposition to that suggested order.
COMMISSIONER ANDERSON: Wlthout objection,
so be it. Any other matters?
MR. I/'IALKER: Yes,
Walker, Idaho Power Company. We
presentation of evidence that we
direct, rebuttal, and surrebuttal
calling of the witness rather than
Mr. Chairman, Donovan
would ask as far as
have presentation of
simultaneously with one
a more formal25
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CSB REPORT]NG(208) 890-s198
presentation where we would separate and spread those out
just for efficiency of proceeding forward, and we've al-so
di-scussed that with some of the intervenors with no
obj ection.
COMMISSIONER ANDERSON: Do I hear any
objections to that? That would be the order. Thank you.
MR. WALKER: Thank you.
COMMfSSIONER ANDERSON: Any other matters?
Well-, werre scheduled for a two-day hearing today and if
there's no objection just procedurally, I'm not going to
schedul-e any breaks. Wer1l come -- probably when I need
a break is when we'll- take a break or when Connie needs a
break, we'l-l- take a break before me even, and we're going
to go ahead and try to do l-unch right about the noontime,
but we'I1 go ahead and l-et the testimony f l-ow as it is
and see if we can get as cl-ose to noontjme as possible so
we can get back.
I don't know if thj-s will require the full
two days, but we're golng
make sure that the record
to try to be efficient today,
is completely formed, but if we
the way we're going to docan get
this, so
that, I
done today, that I s
if not, wel-l-, wetll
do want to introduce
go into tomorrow, and with
our court reporter Connie
and as we'veBucy. She's very good
noticed already, if we
at what she does
speak too fast or j-t's unclear,I 25
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (Di)
Idaho Power Company
it's not going to be me that corrects you, it wil-l
probably be her. She's very good about that, and just be
sure to talk slowly and as clearly as you possibly can or
she will- correct you, and before each witness takes the
stand today, Commissioner Kjellander will do the swearing
of the oath prior to taking the stand.
V[e've already cleared up the fact about
rebuttal testimony and direct. With that, I'm going to
go ahead and we're going to proceed straight with the
Applicant. Go ahead and present.
MR. WALKER: Thank you, Mr. Chairman.
Idaho Power Company cal-Is as its first witness Michael-
Youngblood.
produced
Company,
the whol-e
MTCHAEL J. YOUNGBLOOD,
as a witness at the instance of the Idaho Power
to tell- the truth,
truth, was examined
and testifled as
D]RECT EXAMINATION
BY MR. WALKER:
O Coul-d you please state your name and spe11
your l-ast name for the record?
having
truth,
been first duly sworn
and nothing but the
follows:
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A My name is Michael- J. Youngblood. Last
name is spelled Y-o-u-n-g-b-1-o-o-d.
O And by whom are you employed and in what
capacity?
A I am employed by Idaho Power Company and I
am the manager of regulatory projects.
O Are you the same Michael- Youngblood that
on November Bth, 2016, filed direct testimony in this
matter consisting of 26 pages?
A Iam.
O And did you also file Exhibit No. 1
consisting of 10 pages?
A Iam.
O Do you have any correctj-ons, changes, or
addltions to your testimony or exhibit?
A I just have a change with regard to the
status of one of the items within my direct testimony.
MR. WALKER: And Mr. Chairman, with the
Commission's indulgence, if Mr. Youngblood were al-l-owed
to make that cl-arification or addition at this time.
COMMISSIONER ANDERSON: Proceed.
THE WITNESS: At the top of page L9 of my
direct testimony, I state that a final- decision on the
Company's request to the Blaine County Planning and
/on:-ng Commission for a conditj-onal- use permit was
CSB REPORTTNG(208) 890-s198
YOUNGBLOOD (Di)
Idaho Power Company
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (Di)
Idaho Power Company
scheduled for November 10,
Commissj-on, following that
addltional public hearings
201,6. As an update for the
decision hearlng, the P6,Z hel-d
on December 1-st, 20!6, and
denial of the
the decision to the
on June 29, 2077 .
reviewed the
January 5th, 2071, concluding with a
Company's CUP application.
Idaho Power appealed
Blaine County Board of Commissioners
The Blaine County Board of Commissioners
appeal on August 7, 201,7, and affirmed the P&Zrs decision
to deny the Company's request for a permit.
O BY MR. WALKER: And with that addition, do
you have any other corrections or changes to your
testimony and exhibit?
A I do not.
O If I were to ask you the questions set out
in your direct testimony, woul-d your answers be the same
here today?
A Yes, they would.
MR. WALKER: Mr. Chai-rman, I wou1d move
that the prefil-ed direct testimony of Mr. Michael
Youngblood be spread upon the record as if read and that
Exhibit No. 1 be marked for ldentification.
COMMISSIONER ANDERSON: Seeing no
objection, the testimony is spread on the record.
(The fol-l-owing prefiled direct testimonyof Mr. Michael Youngblood is spread upon the record. )
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O. Please state your name and business address.
A. My name is Michael- J. Youngblood and my
business address is 1-227 West Idaho Street, Boise, Idaho
837 02 .
O. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("fdaho
Power" or "Company" ) as the Manager of Regulatory
Projects in the Regulatory Affairs Department.
O. Pl-ease describe your educational background.
A. In May of L917, T received a Bachelor of
Science Degree in Mathematics and Computer Science from
the University of Idaho. From L994 through 7996, T was a
graduate student in the Executive MBA program of Colorado
State University. Over the years, I have attended
numerous industry conferences and training sessions,
incl-uding Edison El-ectric f nstitute's "Electric Rates
Advanced Course. "
O. Pl-ease describe your work experience with Idaho
Power.
A. I began my employment with Idaho Power in L911.
During my career, I have worked in several departments of
the Company and subsidiaries of IDACORP, Inc., including
Systems Development, Demand Planning, Strategic Planning
and IDACORP So.l-utions. From 1981 to 1988, f worked as a
Rate Analyst in the Rates and Planning
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YOUNGBLOOD,
Idaho Power
Dr1
Company
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YOUNGBLOOD, DI 2
Idaho Power Company
Department where I was responsible for the preparation of
electric rate design studies and bil-l- frequency analyses.
I was also responsible for the val-idatj-on and analysis of
the l-oad research data used for cost-of-service
allocations.
From 1988 through L99L,
and was responsible for the
forecasting functions of the
design, implementation, data
I worked in Demand Planning
load research and load
Company, including sample
retrieval, analysis, and
for the preparation of thereporting. I was responsible
five-year and 20-year load forecasts used in revenue
projections and resource plans as wel-l- as the
presentation of these forecasts to the public and
regulatory commissions.
From 7991 through 1998, T worked in Strat.egic
Planning. As a Strategic Planning Associate, I
coordinated the complex efforts of acquiring Prairie
Power Cooperatlve, the first acquisition of its kind for
the Company in 40 years. From L996 to 1998r ds a part of
a Strategic Planning initiative, I helped develop and
provide two-way communication between customers and
energy providers using advanced computer technologies and
tef ecommunicati-ons.
Erom l-998 to 2000, I was a General Manager of
IDACORP Solutions, a subsidiary of IDACORP, Inc.,I 25
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reporting to the Vice President of Marketing. I was
directly
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Idaho Power C
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responsible for the direction and management of the
Commercial & fndustrial Business Solutions division.
In 2001, I returned to the Regulatory Affairs
Department and worked on special projects related to
deregulation, the Company's Integrated Resource Pl-an, and
fillngs with both the Idaho Publ-ic Utilities Commissj-on
("Commission" or "IPUC") and the Public Utllity
Commissj-on of Oregon.
ln 2008, I was promoted to the position of Manager
of Rate Design for Idaho Power. In that position, I was
responsible for the management of the rate design
strategies of the Company as wel-I as the oversight of all
tariff administration.
In January of 2072, T became the Manager of
Regulatory Projects for Idaho Power, which is my current
position. In this position, f provide the regulatory
support for many of the large individual- projects and
issues currently facing the Company. I provided the
regulatory support for the inclusion of the Langley Gulch
power plant investment in rate base, supported the
Company's efforts to address numerous issues involving
Qualifying Facilities ( "QF" ) as defined under the Publ-ic
Utility Regulatory Pol-icies Act of L918 ("PURPA"),
including the Company's efforts j-n Case No. GNR-E-11-03,
the review of PURPA QF contract provisj-ons. I provided
YOUNGBLOOD, Dr 3Idaho Power Company
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direct testimony for the Company in its Idaho application
for a Certificate of PubIic Convenience and Necessity
("CPCN") for the investment in selective catalytic
reduction controls on Jim Bridger Units 3 and 4, IPUC
Case No. IPC-E-L3-L6, the Company's request to implement
solar integration rates and charges based upon the
initial- 20L4 Study, IPUC Case No. IPC-E-14-18, ds well- as
the Idaho case to update those integration costs with the
2076 Study, IPUC Case No. IPC-E-16-11.
O. What is the purpose of your testimony in this
matter?
A. The purpose of my testimony is to provide an
overview of the Companyrs case and its request (testimony
was stricken) that the Commlssion find it to be in the
public convenience and necessity that Idaho Power
construct a new 138 kil-ovolt (r'kv'r) transmission line and
related facil-ities to provide a redundant source of
energy into the northern portion of the Wood River Valley
north of East Fork Road, j-ncluding the communities of
Ketchum and Sun Va1ley and portions of Blaine County
("North Va11ey"). The North Va11ey is currentl-y supplied
by a 54-year-oId, single-source radial line that
experiences sustained outage line events, which are
projected to increase in frequency. The North Va1ley is
the second largest load center in Idaho Power's service
YOUNGBLOOD, DI 4Idaho Power Company
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YOUNGBLOOD, Dr 5
Idaho Power Company
territory served by one radial transmission 1ine.
The proposed facilities are necessary and required in
order to continue providing rel-iabl-e and adequate
electricity to Idaho Power's customers in the North
Va11ey.
I. O\IERVIE}T
O. Pl-ease provide an overview of the Company's
CASE.
A. In this case, the Company will support its
request for a CPCN by discussing ldaho Power's need to
construct a new transmissi-on l-ine in the Wood River
Valley, providing background information including
extensive public and community outreach and involvement,
and discussing the varj-ous redundant service al-ternatives
considered and l-ine route options that support the
request in this case. In his direct testimony, Company
witness David Ange11 will discuss why the Company must
construct facil-ities between the substations in Hailey
and Ketchum. to meet its continuing obligation to serve
customers located in the North Va11ey. He will- al-so
discuss the Company's long history of planning for a
second transmission l-ine and the cooperative efforts
taken between Idaho Power and the people in the
communitj-es of Sun Va11ey, Ketchum, and Blaine County.
This collaborative process was intended to find agreementt25
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on the purpose and need for a redundant
/
YOUNGBLOOD, Dr 5a
Idaho Power Company
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YOUNGBLOOD, Dr 6
Idaho Power Company
source of energy and to determine the scope and
feasibility of a route that could be obtained and
permitted.
Mr. Ange11 wil-I discuss a number of construction
configurations the Company considered, both standard
practice and non-standard, to provide redundant service
to the North Va11ey, ultimately determining three viabl-e
construction configuratj-ons for further analysis, which
he provided to Company witness
Adelman's direct testimony will
Ryan Adelman. Mr.
detail
detriments of each of the
the costs,
viablebenefits, and
construction
estimates on
configurations,
three additional
as well- as providing cost
options for one specific
Mr. Adel-man concl-udes byconstruction configuration.
identifying both the Company's standard practice
construction configuration for buil-ding a redundant
electrical solution, given the cost estj-mates and the
constralnts of the North Va11ey, ds well- as an
economically equivalent alternative route, which is the
route for which the Company is requesting a CPCN be
issued.
O. What were the three viable construction
configurations for providing redundant service to the
North Va1Iey?
A. As more fully described in Mr. Adelman's25
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testimony, the three redundant service construction
configurations were ldentified as: (1) Underground
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YOUNGBLOOD,
Idaho Power
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Transmission, (2) Overhead Distribution, and (3)
Underground Distribution.
0. Which constructlon confj-guration did the
Company determine as the economic base case for providing
redundant service to the North Va1ley?
A. As described in Mr. Adelman's testimony, the
Overhead Distribution construction configuration was the
lowest-cost viable alternative, as wel-1 as the
traditional or standard practice for providing redundant
electrical- service to an area and therefore became the
basis for comparison of other construction
conf i-gurations.
O. Woul-d the Overhead Distribution base case be
considered one of the typical or standard construction
configurations applied by the Company when addressing the
need for redundant el-ectrical service?
A. Yes. Based on discussion with Mr. Ange11 and
Mr. Adelman, the Company's traditional practice to reduce
the l-ikel-ihood of sustained outages woul-d be to construct
multiple overhead transmission lines (a redundant
transmission source) or to implement distribution
circuits with tie switches in order to continue provi-ding
customers with re]iable el-ectric service. The Overhead
Distribution base case meets these crj-terj-a. However,
while the Overhead Distribution construction
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configuration was the l-owest-cost viabl-e sol-ution and
wou1d provide redundant
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service to the North Va11ey, there wou1d be some
challenges for the actual construction of this route, the
land acquisj-ti-on required for the substation and other
facJ-lities, and aesthetic concerns that warranted a look
at other alternatives. More specifically, ordinances in
Ketchum and Sun Valley requiring that all new e1ectrical
facil-ities be constructed underground would make it more
difficult to construct overhead distrlbution lines
because of the communities' concern of visual impact on
the area.
The Underground Transmission construction
configuration, with a simil-ar range in cost estimates to
the lowest-cost Overhead Distribution base case, would
also provide redundant service. fn addition, the
Underground Transmj-ssion construction configuration woul-d
provide additional- capacity, enabling future growth
within the area. The range in estimated costs for the
Underground Transmission construction configuration was
dependent on the location of the transition point from
overhead-to-underground transmission. The further along
the path that construction can remain above ground
reduces the overal-l- total- cost of the project. As
described in Mr. Adelman's testimony, three separate
options to the Underground Transmisslon construction
configuration, with varying overhead-to-underground
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transition points ("TP"), were analyzed further: TP1,
near the intersection of Elkhorn
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Hospital Drive and Highway 75;
intersection of OwI Rock Road
Road and Highway 15; TP2, near the intersection of
option,
in the
and TP3, near the
and Highway 75. The TP1
of Elkhorn Road, resul-ted
lowest-cost estimate for the Underground
Transmission construction configuration. The cost
estimate for the TP1 option was essentially equivalent to
the l-owest-cost estimate of the Overhead Distribution
base case.
O. Is the TP1 route, dt Elkhorn Road, the option
for which the Company is requesting a CPCN?
A. Yes. The Company's request is for the
Commission to find that the present and future public
convenience and necessity require the construction of a
new 138 kV transmission line and rel-ated facil-ities to
near the intersection
provide a
Valley.
construction of a new
redundant source of energy into the North
Both of the viable options require the
overhead 138 kV transmission line
from the Wood
lntersection
as the Common
River stati-on to a l-ocation near the
of Highway 15 and Ow1 Rock Road, referred to
Route. From that point north, either the
the Overhead Distribution base case would
necessary facili-ties to provide a redundant
TP1 option
provide the
or
source of energy to the
economically equivalent .
North Va11ey, and are both
However, the TP1 option wil-l-
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Idaho Power Company
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provide additional- stability over time as it wil-l- allow
for future growth in customer
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YOUNGBLOOD, Dr 10
Idaho Power Company
demand. The Underground Transmission construction
configuration would provide ful-I redundant capacity of
the existing 138 kV transmissj-on l-ine and would support a
bulld-out demand in the North Va11ey area of 1,20
megawatts ("MW"). The line would provide the ability to
de-energize any section of either transmj-ssion l-ine for
maintenance, inspection, repair r or reconstruction,
without customer interruption. The construction of the
Underground Transmissj-on TP1 option is the Company's
requested route for the Commission's CPCN consideration.
II. EUIIDING ALTERNATI\IES
o.
options
A. Yes, however, at
The estimated cost for TP2
Woul-d the other Underground Transmission
afso provide the same benefits as the TP1 option?
incrementally greater cost.
is an additional $2.1 mil-l-ion
an additional- $5.7 millionat $32.7 million and TP3 is
over the Overhead Distribution base case at $35.7
mil-1ion.
O. Were all communities in agreement with the
sel-ection of TP1?
A. No. There was interest expressed 1n putting as
much of the redundant l-ine underground as possible;
however, representatives for the communities were
concerned about the need to pay for the incremental costs
for the additional underground transmission fine throughI25
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a Local Improvement District ("LID"), which would assess
the
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YOUNGBLOOD
fdaho Powe
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ompany
,DrC
additional- dol1ars based upon the North Va11ey property
values. The Community Advisory Committee ("CAC") was
concerned that it would be very difficult to get an LID
approved.
a. Did anyone in the communj-ty suggest that the
l-ine shoul-d be placed underground regardless of the
l-ocation and cost?
A. At first, some members of the CAC suggested
that there shou1d not be any incremental costs because of
the city ordinances restricting new overhead
construction.
O. What was Idaho Power's response to the
assertion that local communities should not be required
to fund the incremental- costs of non-standard designs?
A. Idaho Power explained to
to buil-d itsCompany is obligated
most cost-effective manner possible. Idaho Power
develops transmission project designs throughout its
service territory that provide the least-cost solution
the CAC that the
infrastructure in the
while adhering
that the IPUC
to consistent standards for service and
allows recovery
the extent
of those reasonably
incurred costs. To that customers or
communities desire the Company to pursue alternate
designs, such as underground transmission at a higher
cost, it is the Company's position, ds previouslya25
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supported by the IPUC,1 that the
lCase No. IPC-3-04-04, Order No. 29634.
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YOUNGBLOOD, Dr 72
Idaho Power Company
customers requesting and benefiting from the al-ternate
design are responsible for the incremental cost
differential- between the l-owest-cost standard practice
option and the
O. What
desired option.
was the CAC's response to the Company's
the incremental- costs should be recoveredposition
from the
A.
North Va11ey
The CAC was
that
possible to get an LID
would consider adding
community?
still concerned that it may not be
approved and asked if the Company
the incremental costs as a
surcharge to the customers' e1ectric bi1ls. The Company
is not generally in favor of col-l-ecting additional- costs
re1ated to meeting the preferences of a community on
customers' electric bills, and at fj-rst resisted.
However, in an attempt to reach a compromise and begin
construction on a much-needed project, the Company
reconsidered its position.
0. What was the result of the Company's
reconsiderat ion?
A. In looking at the three transition-point
optj-ons for the Underground Transmission construction
configruration, the Company considered possible funding
arrangements. The funding options are summarized in the
f ol-lowing table:I 25
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I
YOUNGBLOOD, DI ].3
Idaho Power Company
a:'fiaasitioa Eoiat ftaafag Optioan
Uaargrcatagitio
Doiat
TP1 - Elktt'ora
Road
TP2 - Eospital.
Dr.lve
TP3 - otrl Rock
Etoad
lotaL
CostEstilate
$30.0 M
Iacrerotrf
Coot
$0.0 u
$2.'t v,
s5.7 u
Collootioa tathod
N/A
sr8Oergp
nrtof'Dusetioo,
N./A
s32.'' M 3t./-10 years
s35.7 M
O. Please expfain the taQ,Ie above.
A. For the three transition point options for the
Underground Transmission constructi-on configuration, TP1,
TP2, and TP3, the j-ncremental cost ranges from $0.0 to
$5.7 million. If the 1oca1 jurisdictj-ons supported the
TP1 opti-on, there would be no incremental- costs above the
lowest-cost economic base casei therefore, no additj-ona1
incremental costs would need to be recovered from the
North Valley residents. However, if the communityrs
choice was for either of the other two transition point
options, the additional- incremental costs would need to
be recovered from the customers directly benefiting from
the redundant facilities. The Company proposed that if
the thj-rd option was chosen, the incremental costs of
$5.7 million were of sufficient magnitude that they
should not be recovered as a surcharge on customers'
electrj-c bills, but should be recovered through an LID,
as had been suggested before. However, if the community
wanted option TP2, with the underground transition point
at Hospital Drive, the
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FeetlD
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incremental costs would be approximately $2.1 mill-ion
above the economic base case. The Company agreed that if
the communities chose this option for the transition
point of the Underground Transmissj-on l-ine, the Company
woul-d add a 3 percent surcharge to the North Va11ey
customers' bi11s, with the caveat that any city franchise
fee was first fu11y executed.
0. What does fuI1y executing a franchise fee mean
in this situation?
A. Eor Blaine County, for which a franchise fee is
not applj-cabIe,2 and for the City of Ketchum, which
already has a franchi-se fee at the maximum rate of 3
percent, the Company woul-d add an additional- 3 percent
surcharge to the customers' bill-s. However, for the City
of Sun Va11ey, whlch has a franchj-se fee agreement that
is currently set at 0 percent, the Company requested that
the city raise its franchise fee to the maximum of 3
percent 1n order to col-Iect its respective share of the
total incremental- cost of the TP2 option.
O. Did the Company communlcate these opti-ons to
the respective communities?
A. Yes. I have attached as Exhibit No. 1 copies
of three letters that Idaho Power sent to the
jurisdictions, ds well as to Commissj-on Staff, on May 19,
YOUNGBLOOD, Dr 74
Idaho Power Company
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is not possible for Bfaine County to j-mplement a franchise fee.
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Idaho Power Company
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YOUNGBLOOD
Idaho Powe
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ompany
,DrC
August 5, and August 37, 20L6. These l-etters evidence
the most recent outreach by Idaho Power
jurisdictions in an attempt to reach a
to the
compromi-se or
into the Northconsensus regarding the redundant line
Va1ley. The May 19, 20L6, J-etter invites the
jurisdictions to a "pre-fi11ng settl-ement conference" and
states that prior to making a formal- filing with the IPUC
that the Company woul-d l-1ke to meet and update the
parties regarding current routing options and cost
estimates and to discuss the parties' respective
positions in anticipation of an eventual- IPUC filing.
The parties met, in response to this l-etter, on May 31,
2016. Whil-e the discussions were productive in
establishing a common understanding of the various
positions taken by the respective stakeholder groups, no
compromise was reached.
At the conclusion of the May 31, 2016, meeting, the
jurisdictj-ons agreed to conduct public meetings and
consider the route and cost options for the Hailey to
Ketchum redundant transmission l-ine prior to the end of
August. Company representatives met again on August 3,
20L6, with Sun Vall-ey Mayor Peter Hendricks and staff,
Ketchum Mayor Nina Jones and staff, and Bl-aine County
Commissioner Lawrence Schoen and staff to answer any
additional questions or concerns. The Company also mett25
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individually with a few of the larger customers i-n the
area
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YOUNGBLOOD, Dr 76
Idaho Power Company
who might be most i-mpacted by a 3 percent surcharge,
incl-uding the Sun Val-l-ey Company and St. Lukers Hospital.
In the August 5, 2016, letter, Idaho Power communicated
the offer described above that outlined the associated
estimated cost of the three different overhead-to-
underground transition points and offered that the
Company woul-d consider agreement to
for the i-ncremental- cost associated
18, 2076, the Company attended
town haII meeting to inform the
the redundant source of energy
the various options.
and presented at
option
On August
a Ketchum
public of the need for
and the estimated costs of
a surcharge
with TPz.
O. What was the response to the Company's proposed
options detalled in Table l?
A. In general, the jurisdictions were appreci-ative
of the Company's consideration of al-ternative funding
arrangements. Specifically, there was acknowledgement of
the TP1 option with no incremental costs and the
Company's wil-l-ingness to recover the incremental- costs
assocj-ated with TP2 through a surcharge.
O. Do al-I the jurisdictions support the TP1
option?
A. The Company has not received forma1
notification from any of the three jurisdictions in
opposition to the TP1 option. In order to get aI25
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Idaho Power
DI 77
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confi-rmatlon of the positions of the individual
jurisdictions, the Company sent a l-etter on August 31,
2016, dsking for a written indication of their preference
as to the routing and funding of the proposed line by no
l-ater than September 23, 2016. The Company chose that
date because it provided each jurisdiction with an
opportunity to conduct at l-east one additional decision
meeting prior to providing a response back to the
Company. In the l-etter, the Company stressed that it
belj-eved the Underground Transmission-TP1 option
appropriately bal-anced the col-lective interests of the
communities with the Company's desire to continue to
provide safe, reliable el-ectric service into the future.
The Company requested that the responses from the
jurisdlctions indicate their support, or non-opposi-tion
to, the preferred construction configuration (Underground
Transmission-TP1 ) .
O. What response did the Company recej-ve from the
indlvidual- jurisdictions?
A. On September 29, 2076, the Company received a
l-etter from the City of Sun Val1ey. In summary, the
letter stated that Sun Valley felt it was thoroughly
informed on the purpose and need for the redundant line,
as well as the impacts of potential routing options. Sun
Va11ey stated that at the regular City Council- meeting of
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September !, 20L6, the Council unanimously agreed that
the redundant
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l-ine project was necessary and vital- for its community
and that the best location at which to underg.orrra thr.
line would be near the intersection of Highway 15 and
Elkhorn Road (the TP1 option).
Blalne County did not respond to the Company's
request by the September 23, 20L6, deadline. The Company
had previously fil-ed a request for a conditional use
permit ("CUP") which was before the Bl-aine County
Planning and Zoning Commission ("P&2") . The P&.2 did send
out a notice to the public, and to the members of the
Wood River Citizens' Advisory Committee and contributors
to the Wood River Electrical- Pl-an, inviting them to a
public hearing
details of the
held on October 13, 2076, where the
transmission line project were discussed.
Representatives from the Company
presenting details of the overal-l-
answering questions from
proj ect
the public. A second meeting
October 20, 2076, where the
attended the meeting
to the P&Z and
was schedul-ed and hel-d on
communication was just
Company to
between the P&Z and Idaho Power,
enabling the
transmission
provide very specific detai-ls on
fines versus distribution lines, the
benefits to Hailey area residents, specifics on the
construction process, and details of structures and
routes, etc. The Company updated the P&Z on the CAC
process, the need for the project, estimated costs of thevarious a]ternatives, and took tlme to review the
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Idaho Power
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YOUNGBLOOD, Dr L9Idaho Power Company
route, comparing the existing
with the proposed facilities.
CUP is scheduled for November
Council
facility infrastructure
A final decision on the
10,2016.
O. What response
City of Ketchum?
has the Company received from the
A. While the Company has not received any response
is aware that the
At that meetj-ng,
from the city directly, Idaho Power
met on October 3, 2076.City
the Ketchum Energy Advisory Committee ("KEAC")
recommended that the City Council address its concerns to
the IPUC and request that Idaho Power be required to pay
for an independent cost-benefit and reliability analysis
of al-ternatives to a redundant transmission line. The
KEAC requested that in addition to evaluating local
distributed energy resource and microgrid options, that
the city request consideration of redundant distribution
versus transmissj-on al-ternatives, which it believes,
would a1low for local- generation to integrate into the
grid north of the Hailey substation and move directly
north, whereas, the KEAC claims, redundant transmission
does not.
O. What is Idaho Power's concfusion from these
responses ?
A. While the Company is aware of the concerns
raised by the City of Ketchum, the city's representatj-vesI25
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have not provided any viable alternative to the TP1
option.
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As discussed at length in Mr. Ange11's testimony, the
renewable and alternative sol-utions the City of Ketchum
has suggested are cost prohibitive, with implementation
costs much greater than the Company's proposal. The City
of Sun Va11ey, as well as many other stakeholders in
Blaine County, have
they are supportive
the redundant l-ine
communicated with the Company that
of the TP1 option and understand that
to continue providing
and necessary for the
reliable electric service
North Va11ey. The Company's conclusion is that
option strikes a reasonable bal-ance between
is needed
Company
to the
the TP1
project costs and the goals of minimizing vi-sual- impacts.
The Company bel-ieves that the TP1 option appropriateJ-y
balances the collective interests of the North Val1ey
communities and stakehol-ders with the Company's desire
and obl-igation to continue to provide safe, reli-able
electric servi-ce into the future.
O. Has the Company received any other input from
community members regarding the August 5, 2016, proposal?
A. Yes. Since the May meeting, a number of
stakeholders from the jurisdictions expressed a
preference for TP1, the El-khorn Road underground
transmission line option, with zero j-ncremental costs
above the economic base case and no need for additional
.l-ocal- funding. The TP1 option appears to strlke a
reasonabfe balance between the
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overal-l- proj ect
visual- impacts
0.
request.
A.
North Valley with a
Electricity for the
single, 72.4 mile,
1n 7962 with wooden
impeded by
mountainous
equipment set-up and
al-l- of which results
ccn'-ributes to)'I aval-anche
fn extended repair
l-imitations are
cost and the goal cf minimizing adverse
for the North VaIley area.
rrr. REQIEST S(MMARY
Please provide a summary of the Company's
Idaho Power serves over 91 100 customers in the
10
winter peak load of more than 60 MW.
North Valley area is supplied by a
138 kV transmission l-ine constructed
towers. Access to repair the line is
residential dev,:Iopment. - - Rough and
.t-
terrain that ,imits vehicle accesst
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ti-mes.
impedes
threats,
The
15 existing l-ine' s accessi likely to result
t6 in sustained outages, with the potential- for an extended
outage being catastrophic, not only from the economic
loss of the area, btit the addltional damage that may be
caused by water pipes freezing. It is estj-mated that
71
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ZU reconstruction of the current l-ine to
wood structures with steel-- structures
numerous eight-hour line gutages, with
-l
the line conductor requiring a six tor
outage. Another source of electricj-ty
customers of the Ketchum and
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replace existing
would require
the replacement of
12-week continuous
to serve theI25
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El-khorn substations woul-d be required during the
reconstruction period.
The Company has worked col-laboratively for more than
a decade wj-th the Wood River CAC to develop the Wood
River Va11ey Electrical- Pl-an ("WREP" ) , a comprehensive
plan for future transmission facilities in the Wood River
Va11ey, including the North Valley area. The result was
a plan that recommended Idaho Power move forward with a
series of projects, including: (1) construction of a
North Va11ey project and (2) construction of a third 138
kV line in the south va1Iey. The Company is in the
process of constructing the south va11ey portion of the
overa11 pIan, with the planned completion date in 2071.
The North Va11ey area presents a number of
challenges for the Company's traditional- practices for
providing customers reliable el-ectric service.
Traditionally, the Company woul-d reduce the l-ikel-ihood of
sustained outages by constructing multiple transmission
lines or implementing distribution circuits with tie
switches. But the North Va11ey is congested due to
numerous resj-dences and businesses sited in a valley
which is l-ess than one mil-e wide with mountains of steep
slopes and narrow roadways. In addition, the cities in
the val-ley have approved ordinances limiting development
along the mountains and restricting certain developmentfor aesthetic
YOUNGBLOOD, Dr 22
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YOUNGBLOOD, Dr 23Idaho Power Company
reasons, requiring new el-ectrical facilities in Ketchum
and Sun Val-l-ey to
A number of
be located underqround.
by the WREP and analyzed by
Overhead Distribution base
service options were proposed
the Company, with the
case being determined as the
Iowest-cost viable option. The Overhead Distribution
construction configuration became the Company's economic
base case at an estimated cost of $30 mi1lion, based on
conceptual design l-evel- estimates, includlng a 30 percent
contingency.
With constraints on overhead construction in the
Wood River Va11ey, the Company also considered the
Underground Transmission option with the overhead-to-
underground transition point being located near the
intersection of Elkhorn Road and Highway 75. The total-
construction cost estimate for TP1 option is also $30
million, making it an economic al-ternative to the
Company's base case.
The Company compared this economic base case to the
Underground Transmission construction configuration with
the TP1 option, which is economically equivalent with an
estimated construction cost of $30 million. In
comparison, the TP1 option will provide additional
stability over time as it would allow for future growth
in customer demand. The Underground Transmissj_on
redundant
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construction confi-guration woul-d provide full redundant
capacity of the existing 138
YOUNGBLOOD, Dr 23a
Idaho Power Company
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kV transmission l-ine and would support a build*out demand
in the North Va11ey area of 120 MW. The line would
provide the ability to de-energrze any section of either
transmission l-ine for maintenance, inspection, repair, or
reconstruction, without customer j-nterruption. The TP1
option appears to strike a reasonable bal-ance between the
overall- project cost and the goal of minimizing adverse
visual impacts for the North Va11ey area.
The Company has two compelling reasons that now
require the construction of this 138 kV transmission
line: (1) the increased rel-iability provided by the
redundant source of energy and (2) the need to
reconstruct the existing and aging 138 kV radial-
transmission line without long-term disruption of service
to the North Val1ey. The Company has demonstrated the
need for the redundant line, has worked collaboratj-vely
with the North Va1ley community, evaluated numerous
al-ternatives to t.he viabl-e solutions, and has concluded
with an economic alternative to the l-owest-cost option.
a. What is the Company specifically requesting the
Commission provide?
A. Idaho Power respectfully requests that the
Commission issue an order: (1)specifically finding that
the present and future pubJ-i-c convenj-ence and necessity
requires the construction of a new 138 kV transmissionIine
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YOUNGBLOOD,
Idaho Power
DI 24
Company
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YOUNGBLOOD, Dr 25Idaho Power Company
and related facifities to provide redundant service from
the Wood River substation, near Hailey, into the Ketchum
substation and (2) specifically granting the Company a
Certificate of Publ-ic Convenience and Necessity for the
construction of such l-ine and facilities identified
herein as Underground Transmission-TP1.
O. Is the Company, at this time, requesting a rate
adjustment for
of $30 million
A. No,
recovery of the construction cost estimate
for the TP1 option?
the Company is not seeking any specific
for the facilities invol-ved herein at thisraterecovery
and willtime,
in the
do so in a proper rate recovery proceeding
future.
O. Does this conc1ude your testimony?
A. Yes, it does.
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.A
CSB REPORTING(208) 890-5198
YOUNGBLOOD (X)
I,laho Power Company
(The fol-l-owing proceedings were had in open
hearing. )
MR. WALKER: The wi-tness i-s now available
for cross-examination.
COMMISSIONER ANDERSON: Thank you. We'fl
go
the
ahead and proceed to the intervenors and we'11- go in
A The single source as
of my testimony refers to the
is referred to on
order that was requested earlier. Mr. Greg Adams.
MR. ADAMS: Thank you, Chair.
CROSS_EXAMINATION
BY MR. ADAMS:
a Good morning, Mr. Youngblood.
A Good morning, Mr. Adams.
O Mr. Youngblood, f'm going to ask you a
couple of questions on page 4 of your direct testimony,
l-ine 2L, you state, "The North Va11ey is currently
supplied by a 54-year-oId, single-source radial l-ine that
experiences sustained outage line eventsr" but isn't it
true that the Company's proposed redundant line would
also be served from the same single source from the Wood
River substation?
page 4
radi-a1,
radJ-aI,
line that is providing the energy to
the single
the NorthI25
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
Va11ey.
O But
source of power to
from the north of
you're not
flow into
Ketchum?
proposing a whole new
the valley, for
Itrs still going
example,
to come in
from the south through the Wood River substation; right?
A The Company is proposing a redundant
transmission line to come into the North Val1ey as a
second source of energy into the North Va1ley.
same source as
Through the Wood River substation, the
the existing l-ine; right?
Both of the l-ines woul-d initiate out of
Valley substation, that is correct.
Okay, moving on to page B of your
l-ines 5 to 9, you state that the existing
Ketchum and Sun Val-l-ey would make it more
f\
the Wood River
O
o
test j-mony, at
ordinances in
difficul-t to
Ketchum.
A
0
A
o
in the ci-ties
overhead line
A
about overhead
Page B,
And what
Wel-l-, you
of Ketchum
lines 5 to 9
did you say
state here
and
again that I said?
that the ordi-nances
construct overhead transmisslon through
I'm sorry, you said on page 8?
through those
Yes, I stated
distribution
Sun Val-l-ey would make an
cities more difficult.
specj-fi-caIIy when talking
construction configuration, II25
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CSB REPORTTNG(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
was talking about that ordinances in Ketchum and Sun
Va1Iey requlring that aI1 new el-ectrical- facilities be
constructed underground would make it more difficult to
construct overhead distribution lines because of the
communities' concern of visual impact on the area.
O But isn't it true now, al-so, that the l-and
use laws for the entire county would make it difficul-t to
put in overhead transmission line in the scenic Highway
'15 corridor?
A Irm not familiar with the land use laws of
Bl-aine County.
O Didnrt you just
your testimony that the Blaine
conditional use permit
A r did.
state when you corrected
County Commi-ssion denj-ed a
for construction of the l-ine?
That is correct, I did.
Have you reviewed that Planning and Zonlng
Commission document?
A I have not; however, it is my
understandj-ng that as we are proceeding here today that
the Idaho Public Utilities Commi-ssi-on would circumvent
any lower court or the court of the Planning and Zoning
Commission' s decision.
O Wel-l-, you stated that the Planning and
o
A
0
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CSB REPORTING
(208 ) 890-5198
YOUNGBLOOD (X)
Idaho Power Company
Zoning Commission did deny the conditional use permj-t;
correct?
A That 1s correct. We have not seen the
final order on that, but that is correct.
MR. ADAMS: Mr. Chal-rman, may I approach
the witness with an exhlbit?
COMMISSIONER ANDERSON: You may.
(Mr. Richardson distributing documents. )
MR. ADAMS: Mr. Youngblood, have you had a
chance to review that document?
A I have not. Would you l-ike me to review
the entire document?
O No, just what is it? What does it say it
is?
A It says at the top, "Bfaine County
Planning and Zoning Commj-ssion, Publ-ic Hearings: October
13, November 10, December 7, 2016, and January 5, 201,7,
Public Workshop: October 20, 2076."
O Doesn't it state there up at the top,
and Decision"?" Findings Law
admit this
and Zoning
use permit
of Fact, Conclusions of
A That it does.
MR. ADAMS: Okay.
exhi-bit. This is the
Commission's declsion
so that the record is
I woul-d move to
County Planning
the conditional
Chair,
Blaine
denying
complete on the pointa25
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CSB REPORT]NG
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
MR. ADAMS: And so Mr. YoungbJ-ood,
stated, there is no written decision yet from the
Commissioners affirming thi-s decision of
that Mr. Youngblood made earlj-er.
COMMISSIONER ANDERSON: If there are no
obj ections
MR. ADAMS: This would be Exhibit No. 801
if it's a Rock Rolling Properties exhibit.
COMMISSIONER ANDERSON: If there are no
objections, we'l-1 admit 801 into the record.
(Rock RolJ-ing Properties Exhibit No. 801
was admitted into evidence. )
of County
Planning &
as you
Board
the
Zoning Commissj-on; correct?
A That is my understandj-ng, correct.
O But this decision was affirmed, that's
your understanding?
A That is my understanding, y€s.
O So going back to your statement on page I
that the ordinances in Ketchum and Sun Valley would make
it more difficult to construct overhead transmission in
Ketchum, why is it that the ordinances in Ketchum and Sun
Val1ey are more important than the Blaine County
Commission's decisi-on that there shouldn't be an overhead
line down the rest of Highway 75?
A I don't know or I wouldn't say that they25
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
are more important or l-ess important than the P&.2 and the
Blaine County Commission decision, nor would f say they
are more important than a decision that would come out of
the Idaho Public Utilities Commission.
O Moving on to page 1,6 of your testimony,
Mr. Youngblood, Ii-nes 23 to 25, you state here, "The
Company has not yet received formal notification from any
of the three jurisdictions in opposition to the TP1
option." You're referrj-ng here to Blaine County,
Ketchum, and Sun Va1ley; correct?
A That is correct.
O And TP1 is transition point one where the
1j-ne woul-d go underground at El-khorn; correct?
A That is correct.
O Isnrt it now true that we need to revise
this statement with respect to both Ketchum and Blaine
County?
A I do not believe so in the sense that when
this was written, when thls testimony was written, it was
in response
individual-
to the l-etter that had been sent to the
parties,
at thatCounty,
formal
the Sun Val1ey,
point in time we
of any opposition
we have received
received
to that. I stillnotification
do not believe that
and
Ketchum,
had not
and Blaine
formal opposition to
the transition point one line from either Ketchum ort25
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CSB REPORTING
(208 ) 890-5198
YOUNGBLOOD (X)
Idaho Power Company
Blaine County. We did receive a l-etter from Sun Val1ey
that stated that they were in support of transition point
one.
O You don't
Commlssioners' rejection
formal opposition to the
proposed here?
A I believe
think the BIaine County
of the conditiona1 use permit is
transitj-on point one proposal- as
that it was a flnding of that
the Company in a
think that the City of
in oppositionand testimony
Commission, but
formal- way as we
it has not notified
had stated in my testimony that they
were in opposition of that.
O And you don't
Ketchum's part.icipation here
to the proposal- is forma1 opposition?
I stated, this was inAS responseA Again,
to our letter to those requesting a
they were in
stated that
Trm sorry,
they did not
formal
opposition
they would
the Idaho
respond
opposition
it?
entities
determinatlon of whether or not
or not. The City of Ketchum had
file comments to the Idaho Power
Public Util-ities Commission, but
directly to us in response to that letter.
O So if there were formal local
to the Company's proposal, would that change
A Wou1d it change what?
O Your proposal here today.I 25
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CSB REPORT]NG
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
asking
of the
A No, it would not.
O No, it woul-dn't; so you' re basically
the Idaho Commission to preempt the determj-nations
l-ocal- governments?
A We are here today to ask the Idaho Public
Utilities Commission to make a decision whether or not
the Company in order to contj-nue to serve the people of
North Val1ey with rel-iab1e service would provide a CPCN
or certj-ficate of public convenj-ence and necessity for
the underground transmissj-on line at transition point one
as the Company had proposed.
O And in your view, that would preempt what
the Bl-aine County Commissioners just did, rejecting the
conditional use permit?
A That is my understanding from my counsel
that the decision of the Publ-ic Utilities Commisslon
would render moot the decisions of the other courts.
O And are you aware of any precedent where
the Idaho Public Utilities Commission has preempted a
local authority on an issue like this?
A I am not aware whether they have or have
not.
O On your testimony on page L!, you discuss
loca1 funding options, and you state on line 2 Lo 3, "The
Community Advisory Committee was concerned that it would25
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
be very difficul-t to
approved, " and then
next two pages about
options. Do you see
A I do.
O Soif
get a local- improvement district
the discussion goes on through the
Ioca11y-assigned costs and different
that?
there's no local- improvement
distrlct, are you asking the PUC to unilaterally assr_gn
locaIthose costs above whatever the baseline is to the
community?
A The Company would request that any
recoveredincremental cost above the baseline wou]d be
from those customers who would directly benefit from the
new l-ine, that is correct, that those costs, those
i-ncremental costs, would not be spread to the body of
ratepayers of Idaho Power Company. That has been
supported in previous hearings, in particular the Eagle
transmission line, fPC-E-04-04, I believe, but Irm not
positive of that number. Yes, it j-s.
O Okay, we1l, you state here on page 13 at
line 7, "If the l-ocal jurisdictions supported the
transition point one option, there woufd be no
incremental- costsr" but now that we've got the order from
the Bl-aine County Commission not supporting that opti-on,
where does that leave us?
A I believe we are exactly 1n the same placeI25
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CSB REPORTING
(2oB ) B9o-s198
YOUNGBLOOD (X)
Idaho Power Company
as we were before prior to that decision.
O What if the that
the basel-ine cost is
PUC agrees with its Staff
around $18 mi11ion, are you
difference for any
only
theasking them to
undergroundi-ng
A
Commi-ssion.
O
Sun Va11ey, the
A
0
testimony?
A
o
assign
in this case ?
The Company wil-l- await the decision of the
Okay, you referenced earl-ier a l-etter from
City of Sun Valley; right?
Yes.
And you discuss that on page L7 of your
Yes
And it states here on l-ine 20 to 23 that
the City
stating
and need
that the
Powerts
of Sun Val1ey sent a letter to
that it was "thoroughly informed
for the redundant line. " Isn't
Idaho Power
on the purpose
it true, though,
City of Sun Valley was just
assertions that the redundant
accepting
line was
Idaho
necessary?
A I can only speak for what Sun Val-l-ey put
in its l-etter and Sun Va11ey Company said that they
were they fel-t that they were thoroughly informed of
the purpose and need for the redundant l-ine as wel-l- as
the impacts of potential- routing options.I 25
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
O Does the
power quality engineers
redundant transmission
Valley have its own
the need for a
City of Sun
to evaluate
A I bel-ieve there was an assistant of some
sort that was helping them in their decision, that is
correct.
O Did Idaho Power inform the City of Sun
l-ine?
existlng l-ine has historically good
Yes.
Did Idaho Power inform the City of Sun
option is to simply construct a temporary
al-l-ow reconstructj-on of that existing
Valley that the
reliability?
A
0
Valley that one
line that woul-d
l-ine?
A That was not an option for redundant
service, DO.
0 Right, it wasn't an option for redundant
service, but did Idaho Power inform the City of Sun
Valley that that woul-d be one option to reconstruct the
existing l-ine and have the same power quality that's
existed in the past?
A The City of Sun Val-l-ey was aware that the
existing line was in need of repair and the Company has
made no qualms about the fact that that line does need to
be reconstructed; however, when you say that j-t was to25
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
receive the same quality of servj-ce as it has in the
past, the Company has proposed the redundant l-ine to
improve the reliability of the existing l-ine regardless
of its performance in the past.
A customer base of 91 000 customers in the
North Valley served by a single radia1 l-ine is at risk of
that line going out and not having provislon of e1ectric
service, so the Company has proposed a redundant
transmission 1ine, so regardless of the need for the
existing line to be reconstructed, the Company stil-1
believes a redundant line is needed and necessary in
order to continue to provide
service to the North VaIley.
O So I take it
reliable and safe electric
from that
inform the City of Sun Val-l-ey that one
1nsta11 a temporary transmission l-ine
the Company dld not
possibility was to
to allow for
reconstruction of the existing l-ine; is that correct?
A I take issue with your characterization of
that. That is not one optj-on. One option is not to
provide a temporary l-ine to reconstruct the existj-ng
line.
O Isnrt that the position that the PUC Staff
witness Mike Morrison determined was the l-east cost
solutj-on to the problem here?
A I believe that is what Mr. Morrison has int25
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his testj-mony; however, that is not an option to provide
redundant service. That is a construction methodol-ogy to
go ahead and repair the existj-ng l-ine, but the existing
line woul-d still be a single radial source of electricity
for the North Va11ey. The Company believes that a
redundant line is needed in order to continue to provide
the rel-iable el-ectric service to the North Va1Iey.
O f thought Mr. Morrison stated that the
redundant line wasnrt the cost of it did not justify
the benefits. Don't you think that the local-
municipalities up there would have been interested to
know that that was an option?
A You wou]d have to ask Mr. Morrison if he
provided that. He provided that information in his
testimony. The Company di-sagrees with Mr. Morrison's
eval-uati-on of whether or not the cost of the redundant
l-ine is worth the risk that is associated with losing
electric service to the North Va1Iey.
O So did Idaho Power inform the Blaine
County Commj-ssion
MR. WALKER: Objection, Mr. Chairman.
He's asked this question numerous times now and the
witness has provided his answer.
MR. ADAMS: That's not true. I asked
about the City of Sun Va11ey. Now I'm asking whether
CSB REPORT]NG
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
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CSB REPORT]NG
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
Idaho Power informed the Blaine County Commission of the
option to construct a temporary line in order to
reconstruct the existing l-ine.
COMMISSIONER ANDERSON: f'm going to let
you continue, but Irm pretty clear what the answers are
here.
MR. ADAMS: Wel-l-, f I l-l- move ofl, then,
Chair.
O By MR. ADAMS: Mr. Youngblood, on page 25
of your testimony concluding, you speak about rate
recovery for the l-ine and actualJ-y, what you state is the
Company is not requesting rate recovery of the $30
mil-l-ion line at this time.
A That is correct.
O Is the Company
in rates
proposing to cap the amount
that lt wil-I recover on the project through the
CPCN that you're proposing?
A It is not part of our proposal-, ho.
O So the cost could in fact be in excess of
$30 million?
A And/or l-ess than $30 milIion.
O And these amounts wou1d be placed in rate
base,'correct?
A At an appropriate time the Company woul-d
come back before the Commission to request recovery ofI25
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CSB REPORT]NG
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
the prudently-incurred costs to install the transmission
line through a rate recovery hearing, correct.
O And most of it woul-d be placed in rate
base; correct?
A That is correct.
a And the Company would earn its authorized
rate of return on the undepreciated balance?
A If it 1s inc1uded in rate base, that is
correct.
O And whatrs the Company's authorized rate
of return, approximately?
A Oh, I believe itrs 7 '- I don't know,
1.86; is that correct? Yes.
MR. ADAMS: Thank you, Mr. Youngblood.
Chair, I don't have any more questions for Mr.
Youngblood.
COMMISSIONER ANDERSON: Thank you, Mr.
Adams. Mr. Richardson for Kiki Tidwe]l-.
MR. RICHARDSON: Thank you,
Mr. Chairman.
I 25
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CSB REPORTING(208) 890-5198
YOUNGBLOOD (X)
fdaho Power Company
BY MR. RICHARDSON:
questions, is the Company
CROSS-EXAMINATION
Good morning, Mr. Youngblood.
Good morning, Mr. Rj-chardson.
Just to fol-l-ow up a couple on Mr. Adamsr
o
A
o
been made exactly when the time of that
currentl-y planning to
line?reconstruct
A
that yes, we
reconstruct
read.
the existing
My understandlng from our
do need -- we do know that
the existing l-ine; however,
engineers is
we need to
no plans have
would occur.
of questions
assume you've
O So the answer is Do, you're not currently
planning to reconstruct the existing line?
A That is my understanding. Mr. Ange11
woul-d be better suj-ted to answer that question.
O So the cost of reconstructing the existing
line is not included in this $30 mi1lion estimate, is
ir?
That is correct.
Let's start with
about the Company's application,
a couple
which I
Yes.
First of all, is a transmission l-ine a
A
0
A
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
source of energy?
Yes.
Are you an electrical engineer?
f am not.
O So if I buil-d a transmission l-ine out in
the desert that's not connected to anything, where does
it get its energy?
A It would not; however, it would provide
path when it is connected to a source of energy,
generation source.
A
O
A
a
O So that sort
transmission line a source
A And again, I
of begs my question. fs a
of energy?
would state that a source of
in the desert would not beoutenergy that is sitting
abl-e to reach its end result or its customers without the
transmission l-ine r so it ' s
i-n order to provide energy
O So maybe you
part of the integrated system
to the customers.
didn't
was if I built a transmission line
hear my question. It
out in the desert not
connected to anything, what's the source of energy?
A I take issue only with the question is why
would you build a transmission line out in the middl-e of
the desert with no connectivity to any generatj-on plant?
a But I get to ask the questions. If you
built a transmission line in the middle of the desert notI25
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
connected to anything, how is it
A I understand what
Mr. Richardson.
a source of energy?
you're trying to get dt,
Can you answer the question?
I would still state that the transmission
a path from the generation source to the
therefore, it provides a source of energy
o
A
Iine provides
customer and,
to the customer.
threats that the
are aval-anches.
O The application on page 4, one of the
I
Company identifies to the existing line
Do you recalI that?
do.A
O And do you recall- how many avalanches have
taken out the exlstlng l-ine since it was flrst
constructed?
A I do not know for sure, but I would assume
none.
0 None. A1so, according
application, the need for a redundant
to Company's
source of energy,
assuming a transmi-ssion line is a source of energy, into
various levels sincethe North Va11ey has existed on
approximately 7973, and to refresh your memory, thatrs
the application on page 15. Do you recall that?
A I do.
O However, j-sn't it true that the Company
on
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CSB REPORT]NG(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
specifically told this Commission 22 years fater in 1995
that there is no need for a new 138 kV transmission line
to provide additional el-ectrical capacity to the
Ketchum/Sun Valley area?
A In response
with regard to buil-ding a
to public concern
transmission line
and issues
at that point
in time, the Company did an evaluation and did come to
the conclusion that at that point
redundant
in time, there was no
need for an additional-line; however, it has
been 22 years l-ater. The existing wood poles that were
constructed that were first put in place in !962 have
continued to deteriorate over the past 22 years, have
continued to be receive woodpecker damage. There's
concerns with regard to the existing l-ine and so that is
why the Company now states that one of the reasons that
we're requesting a CPCN for a redundant l-ine is that we
do need to stj-ll reconstruct the existi-ng li-ne.
O So I take it the answer to my question is
y€s, it is true that the Company specifically told the
Commission 22 years after L913 that there was no need for
an additional- l-ine; correct?
A That was the Company's statement at that
time in response to the public outcry with regard to
building a transmissj-on line at that point i-n time. The
Company had a1ready received a CPCN for a transmissiont25
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CSB REPORTING(208) B90-s198
YOUNGBLOOD (X)
Tdaho Power Company
Iine at that point in time and the Company responded to
point in time with athatthe public outcry at
reevaluation and an assessment that said that it did not
need one at that
0So
public outcry or
exi-sting line was
A The
time.
it didn't need the fine because of
it didn't need the line because the
adequate?
Company took j-nto consj-deration the
public outcry at that point
position and the strength of
point in time and determined
transmission, a
point in time.
in time and reevaluated the
the existing line at that
that they did not need a
redundant transmission, line at that
I'm not cl-ear, whatOSo
"public outcry"?
a new l-ine?
do you mean by
obviate the need forDoes public outcry
A There were concerns at that
with regard to the aesthetic impacts, where
would be located. There was not agreement
where the line would be located and various
that.
0 So there's
point j-n time
the line
with regard to
things like
there
no public outcry anymore?
are stil-l concerns from the
public, some
No,
of the
sltuation; however,
with regard to the aesthetic
22 years has passed. The
public,
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existing l-ine has continued to deteriorate. The size of
the community has grown up there. The load has grown up
there. The Company bel-ieves that at 60 megawatts of peak
capacj-ty wit.h 9,000 customers being served by a single
radial 1ine, that is a risk that the Company i-s
suggesting should not be incurred and that we are
proposing a redundant line to reliably serve those
customers.
O So the existing line was in sufficiently
good repair in 1995 that you didn't need to replace it;
correct?
A That is my understanding of the assessment
at that time.
O But now itrs in such disrepair that it
needs to be replaced?
A It has been another 22 years and it has
continued to deteriorate, yes.
O And that's according to your testimony?
A That is correct.
O But yet, itrs still not slated to be
repaired?
A The exact timing of when it is repaired
has not been determined to my understanding; however,
again, f wil-l- say those questions are better answered by
Mr. Ange11, but it is my understanding that y€sr the
CSB REPORTING
( 208 ) B 90-s1 9B
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Idaho Power Company
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CSB REPORT]NG(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
Company does know that that l-ine needs to be repaired and
it will- be repaired at some point in tlme.
O But we don't know when?
A I do not know when.
O So what happens to the North Va11ey if
there's redundant transmission lines 1f the Wood River
substation is disabled for whatever reason?
A What reason would the Wood River
substation be disabl-ed?
a We1I, I can think of a lot of reasons.
Can you think of any reason why a substation would be
disabled?
A I think that the chance or risk of the
Wood River substation being disabled are very, very
s1im.
O Of course, that wasn't
question isn't
what happens to
redundant l-ine
about probabilities.
the North Va11ey
if the Wood River
question. The
question was
there I s aeven
my
The
if
substati-on is disabled
for whatever reason?
A
of electricity;
would not have
o
electricity as
Wel-l, again, there would not be any source
so, therefore, the Wood Rlver Va11ey
el-ectricity at that poj-nt in time.
And even with a redundant source of
you describe a transmission l-ine?I 25
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CSB RBPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
A If the Wood
not in service, even though
Iow of that occurrr-ng,
So al-so
that
on the
Company states that it is "not
any city or county permitting
that?
River Va1ley substation was
the risk would be very, very
would be the case.
application
seeking to
processes. "
at page 23, the
avoid or thwart
Do you recall
I do.
And, of course, you discussed with Mr.
Adams that Blaine County Planning and Zoning has denied
the Company's conditional use permj-t application;
correct?
A I do.
O And you also discussed with Mr. Adams that
the Blaine County Commission has affirmed the Planning
and Zoning Commlssion in its denial- of the condj-tional
use permit,'correct?
A Correct.
O Is it your intention based upon the
assertion in the Company's application that it does not
intend to thwart any city or county permitting processes
to now withdraw your application for a conditional use
permit?
A It is not my understanding that the
Company would withdraw that. The Company woul-d still
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CSB REPORTTNG
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
request a conditional use permit perhaps based upon the
Commlssion's decision. That decision, though, is a 1ega1
one that I'm not qualified to answer.
O Of course, it wasn't a 1egal question.
The question was the Companyrs application says it is not
seeking to avoid or thwart any city or county permitting
processes. fs it your opinion that the Company
proceeding with its certificate of public convenience and
necessity application is not thwarting Blaine County's
permitting process?
A That is correct. That is my
understanding. The Company had always said that it would
continue to look for al-I continue to do all the
permitting, conditional use permitting,requJ-rements and
the Pub]icthat the Company still needed to come to
Utilities Commission for a certificate of public
convenience and necessity.
O So explain to me how proceedj-ng with your
CPCN application, that's CPCN, certificate of public
convenience and necessity, explain to me how your
proceeding with your CPCN application doesn't thwart
Blaine County' s decisi-on.
A When the Company filed its CPCN here, the
Company contj-nued to request a conditional- use permit for
Blaine County, so there was no intent to thwart thet25
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CSB REPORT]NG
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
decision of the BLaine County Commission.
O But that was before the decisj-on was
made?
A When we filed this docket, that is
correct, but that does not change anything.
O Pardon me?
A That
I stated before, it
of the Idaho Public
a CPCN, would make
null and void.
a And how is
decision nu1l and void not
does not change anything. Again, ds
is my understanding that the ruling
Utilities Commission, if they provide
the decisions of the County Commission
continued
It did not
A And again,
to request a CUP
intend for its
making the County
thwarting their
as I stated, the
from the County
Commission's
decision?
Company
Commission.
decision. That decision
here to thwart that
forward and thi-s
response to a
that essentially this
the decision of the
filing
has gone
decision w111 go forward as wel-I.
O And you testlfied in
questi-on from Mr. Adams, I believe,
Commission has the authority to trump
Commissi-on.Bl-aine County
A That is my understanding.
O I guess it's a matter of semantics whether
that's thwarting or not; correct?Z)
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
A That may be, but I , again, sdy that the
be going to the CountyCompany's intent wilf continue to
different cities to provide the necessary
How do you plan to do that?
As
Commission, the
permitting.
o
A
o fsn't that done? You say you're going to
continue to seek permitting from --
A No, I bel-ieve city permitting, agaj-n, Mr.
Ange11 or Mr. Ade1man wil-l- be able to testify to that
more c1ear1y, because they are the project manager of
that project, but they would be able to speak to that
more c1ear1y.
O So when you said that the Company is sti1l
pJ-anning to seek permitting from the County, you rea11y
weren't aware of what you were testifying about?
A Mr. Richardson, you're aski-ng me questions
about the application, so when you're saying f was not
aware, the applicati-on was not my testimony here.
O Well-, letrs refer to page 4 of your direct
testimony where you state that you are testifying in
support of the Company's application for a certificate of
public convenience and necessity; correct?
A Correct.
O And also on page 4 of your directt25
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
testimony, you state that the Company's request is being
made pursuant to two specific ldaho Code sections and
that would be Idaho Code Section 61-508 and 6L-526;
correct?
Correct.
And I assume because you've testified as
to those two Idaho Code sections that you've read them;
correct?
A I have, yes.
O Then do you know, then, that Section
61-508 has nothing to do wi-th a certificate of public
convenience and necessity; correct?
A I actual-Iy get them confusedr So I bel-ieve
that is correct. I be]ieve i-t' s 526 that has to do with
the certj-ficate of public convenience and necessity.
O So 508 doesn't address the certificate of
public convenience and
A
O
A
0
A
Yes, I
Pl-ease
necessity,'
woul-d have
correct ?
refresh my memory.
to do that.
to
take a moment
61-508.
If someone can provide me a Section
MR. RICHARDSON: f never leave home
COMMISSIONER RAPER: Me neither.
THE WITNESS: Okay, I've reread it.
without it.
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
O BY MR. RICHARDSON: So
that Sectj-on 61-508 has nothing to do
of a certificate of public convenj-ence
A That is correct.
woul-d you confirm
with the issuance
and necessity?
0 And then you also know, don't you, that
Section 61-508 does not al-l-ow for a utility to make an
appJ-i-cation to upgrade its facilities; correct?
MR. WALKER: Mr. Chairman, I'm going to
object at this point. Mr. Youngbl-ood j-s not an attorney.
He's being asked Iegal interpretation of a statute.
That's far beyond the mere recitation of citation to Code
that appears j-n our application and mirrored in his
testimony.
COMMISSIONER ANDERSON: Mr. Richardson.
MR. RICHARDSON: Mr. Chairman, f'm willing
to withdraw this line of questions if we strike Mr.
Youngblood's testimony beginning on page 4, line 10, over
through page 5, l-ine 5, but short of that dramatic
result, I think Mr. Youngblood is familiar enough with
the statute to respond to my questions. I'm not asking
him to interpret them, but just to tell us what it says
bl-ack l-etter law there.
COMMISSIONER ANDERSON: Counsel.
MR. WALKER: Well, I'm confused. I didn't
hear any basis to be striking testimony other than just aI25
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CSB REPORTTNG
(208 ) 890-5r-98
YOUNGBLOOD (X)
Idaho Power Company
mere request and my objection still stands that Mr.
Youngblood is not an attorney and being asked detailed
interpretation about statutes is beyond
MR. RICHARDSON: Mr. Chairman, perhaps I
can rephrase the question to avoid any suggestion that
I'm askj-ng the witness to interpret the Code section.
COMMISSIONER ANDERSON: Pfease.
MR. RICHARDSON: Thank you,
Mr. Chairman.
O BY MR. RICHARDSON: Mr. Youngblood, why
don't you just read into the record the first
parenthetical, the first line of that section?
MR. WALKER:
read
I obj ect.
Idaho Code
not necessary
the record.
of the Code
It's
intoto have Mr. Youngblood
The Commi-ssion can take notice from citation
as to what it says.
MR. RfCHARDSON: Mr. Chairman, the witness
presented this in his direct testlmony. If he can't
answer questions about it, which he's already testified
that he's read it, I think f 'm entitl-ed to ask him to
understand what i-t means.
COMMISSIONER ANDERSON: Mr. Richardson, I
believe that I have to agree that I think that Mr.
Youngblood has answered the questions to the best of his
knowledge and not being an attorfley, I do think thatI25
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
you're putting a bit of a burden on him to try to answer
things of a more legaI nature and I'm going to have to
rule that this I do agree with the objection.
MR. RICHARDSON: Give me a moment,
Mr. Chairman.
COMMISSIONER ANDERSON: Mr.
perhaps a solution to this is if there was
just strike line
Idaho Code 61-508
13 where it begins with,
and 6l-526," and ffd like to hear from
the AppJ-icant's
problem.
counsel on that, but that might sofve the
RICHARDSON: Right, that
I would l-ike to explore
but if the Chai-r' s desire
Richardson,
the ability to
"pursuant to
was my
these issues
is to simply
that would
MR
al-ternative reply.
with the witness,
strike the reference to the Code sections,
certainly be acceptable.
COMMISSIONER RAPER: Clarification for Mr.
Walker, so Mr. Richardson, you asked to strj-ke almost an
entire page of testj-mony. My interpretation of what the
Chair was saying was strike the reference to the Code, so
the assertions are still made but without the Iegal
basis, are you still asking to strike the entire thing?
MR. RICHARDSON: No, Commissioner Raper, I
bel-ieve the Chairman narrowed my motj-on to strike
significantly, but Irm okay with that.a 25
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
COMMISSIONER RAPER: Okay, thank you for
the clarification.
MR. WALKER: If the Commission desires to
strike starting on Youngblood's dj-rect page 4, line 13,
after the comma and strike "pursuant to Idaho Code
Sections 61-508 and 6l-526," those particular words,
Idaho Power has no objection, with the proviso that those
al-so appear in the application and the Commission can
take notice of its own authority referenced by those
statutes.
complicate this
actually l-eave
COMMISSIONER ANDERSON: And actually t.o
a little bit more, I believe we could
in
MR
place 67-526. It does
RICHARDSON: That was
actually --
going to be my
I wou]d benext line of questj-ons, Mr.
happy to l-eave 526 and then
Ieave that in his testimony.
Chairman, but
proceed and see if we can
That would be perfectly
acceptable to me, Mr. Chairman.
COMMISSIONER ANDERSON: Any objections to
that, counsel?
MR. WALKER: I'm a littl-e confused as to
what's going on now.
COMMISSIONER ANDERSON: If we were to
strike only the Section 508 and leave intact 67-526.
MR. WALKER: No objection.o 25
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CSB REPORT]NG
(208 ) 890-s198
YOUNGBLOOD (X)
fdaho Power Company
COMMISSIONER ANDERSON: Without objection,
that's what we wil-l- do.
MR. RICHARDSON: Thank you, Mr. Chairman.
Sorry about that confusion for you.
O BY MR. RICHARDSON: Mr.Youngblood, you
testimony therereference Section 67-525 in your direct
on page 4; correct?
A Correct.
O And is it your understanding
take it?
and you've
read that section, I
A I have previously,yes.
the Idaho Code deal-s0 And that section of
with certificates of public convenience and necessity;
correct?
A Correct.
O And you are aware, are you
apply when the
not, then, that
Company is
in which it is
that Section 526 does not
seeking to extend
already providing
MR
objection to the
to 526.
service within a county
service; correct?
. WALKER: Mr. Chairman, I renew my
almost exact same l-ine of questioning as
COMMISSIONER ANDERSON: I created a bit
more of a monster here than I needed to. I think Irm
going to back to the original request of striking bothI25
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
and that's what we're going to dor so line 13, we'f l-
strike both those sections and I concur with counsefor of
the Applicant.
MR. RICHARDSON: Thank you, Mr. Chairman.
I'Il- proceed on with a different line.
O BY MR. RfCHARDSON: So earlier in your
discussions with Mr. Adams, I think you made it cl-ear
that the City of Ketchum has expressed opposj-tion to your
application and that Blaine County has also expressed
opposition to your applicatj-on; correct?
A I believe I stated earl-ier in my testimony
that at the time when we had filed here that we had not
received direct indication from the City of Ketchum nor
Bl-aine County in response to our l-etter that they were in
opposition.
O That wasn't my question. My question was
you do agree, do you not, that the City of Ketchum has
expressed opposition to your application and that the
Blaj-ne County has also expressed opposition to your
appJ-ication; correct?
A I believe what you asked me was that in my
questioning with Mr. Adams and he
testimony that it was in response
had not received direct indi-cation
directed me to my
to our letter that we
of their opposition.
Ketchum hasIt is true that we have that the City of25
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
expressed
and that
their desire to not have the transmission line
they have petitioned here
O So and also Bl-aine
construction of this
in this case.
County has
redundant
expressed
f ine;opposition to
correct?
A Blaine County affirmed the decision of the
Ps,Z not to provide
O That
the conditionaf use permit.
means they're in opposition to the
redundant line; correct?
A I woul-d state I do not know the reasons
that the conditional- use permit was denied.
read Exhibit 801?O Have you
A What is
O Exhibit
conditional- use permit
A Is this
earlier?
O It was.
Exhibit 801?
801 gives you the reasons the
was denied.
the one that was handed to me
A I have not read this, no. I stated that
at the time. I read the top heading on it.
O So you haven't read Blaine County's
decisj-on rejecting the Company's application?
A I have not.
O But you do know it did issue that
decision?I 25
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A I do.
O Okay; so of the jurisdictions in the area,
that sort of 1eaves Sun Va11ey, the City of Sun Va1ley,
as an outlier, doesn't it?
A Of the three, yes; however, there are
other entities that have provided indications of support
for the l-ine.
O Other cities between the substation and
the City of Sun ValJ-ey?
A Not other cities, other entities, other
customers.
O Right. fn your testimony you refer to the
local- support and specifically you reference a l-etter
from the Mayor of the City of Sun Valley at pages 71 to
18; correct?
A Yes.
MR. RICHARDSON: Mr. Chaj-rman, the
fol-l-owing questions wil-I be in aid of a possible motion
to strike portions of Mr. Youngbl-ood's testimony.
0 BY MR. RICHARDSON: Mr. Youngblood, would
you please refer to Exhibit No. 3l-8, which is an exhibit
in Mr. Hecklerrs prepared prefiled testimony?
A I do not have that before me.
COMMISSIONER RAPER: Do you want to
provide it?
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
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YOUNGBLOOD (X)
Idaho Power Company
O BY MR. RICHARDSON: Do you have that
exhibit in front of you now?
A I don't have that before me.
MR. RICHARDSON: I would ask if your
counsel can provide it to you.
MS. NUNEZ: Chair, I have a copy 1f
someone would l-ike to use mine.
COMMISSIONER ANDERSON: I don't believe
j-t's the three Commissionersr responsibility to get
information back and forth. If the questlon is going to
be asked if someone has seen something, Iet's make sure
we have a proviso
MR.
for providing that document.
RICHARDSON: Thank you, Mr. Chairman.
It was my hope that the
the other witnesses.
witness had read the testimony of
(Mr. Adams approached the witness.)
0 BY MR. RICHARDSON: Now, Exhibit 318 is
actually a response to a discovery request by
Ms. Tldwell, her discovery request No. 1,9; correct?
A That is correct.
O And you prepared this document, di-d you
not?
That is correct.
And you're sponsorJ-ng it?
I am not sponsoring this document, DO.
A
O
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CSB REPORTING(208) 890-5198
YOUNGBLOOD (X)
Idaho Power Company
O Doesn't this document say that it's being
sponsored by you at the very last line?
A The response to thj-s request
It is not so when we had data requests, I
is sponsored.
sponsored
is not partthe response to this data request, but this
of my testimony and I'm not sponsoring it,
A So you deny havi-ng prepared
t.his exhibit?
A I do not, sir.
and sponsored
O Wel-l-, why don't you read the first
question at the top of the first page of Exhibit 318.
A "Request for Production No. 19: The
Company's applicatj-on states at page 11 that 'Sun Va11ey
Company"' "'Sun Va1ley stated that at their regular
City Council meeting on September 1-, 20L6, the councj-l
unanimously agreed that the redundant line project was
necessary and vltal- for its community.r The Mayor of the
City of Sun Va11ey stated at the referenced meeting that,
"It is not a vote, it is an expression of our wishes as
far as how they will tackle this project that they are
mandated to do to provide us with power. They, Idaho
Power, have decided that they need to do this. They are
asking us to think about how we want it done.' Pl-ease
reconcife the Application's assertion that the City of
Sun Va1ley 'agreed that the redundant l-ine project was
no
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
necessary' with the Mayor's explanation that the need for
the line was already 'decided' by Idaho Power and that
the City Council was only asked to 'think about how we
want it done.'"
O
this question;
A
o
Thank you, and you prepared the answer to
right ?
That is correct.
So would you please read the second
answer beginning with, "The l-etter is an
Could you read that into the record,
Yes. This is written this is in
sentence of
expression.
please ?
A
response to
Idaho Power
the letter that was
and f state on the
your
. . t'?
sent from Sun Val-l-ey to
second paragraphr "The
Hendricks, Mayor of theleLter,
City of
signed by Mr. Peter M.
Sun Val1ey"
O I'm sorry, I wanted you to read the second
sentence of your answer which begins, "The letter is an
expression...."
A "The l-etter is an expression of the City's
official- acti-on, and the words and contents of the l-etter
speak for themsel-ves. "
O And so do you stand by that statement
today that the Mayor's l-etter speaks for itself and needs
no interpretation?I 25
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A Yes, I would say that I woul-d stand by
that today. The l-etter continues to state that at the
regular City Council- meeting of September 1-, the Council-
unanimously agreed on the following project scope and
components and it outlines those here, "That the
redundant line project is necessary and vital- for our
community, which is geographically isol-ated, has
substantial wil-dfire risk, rel-ies heavily on tourism
during the winter, and experiences severe winter
weatherr " and the letter continues, "That the best
l-ocation at which to underground the l-ine is near the
intersections of Highway 75 and Elkhorn Road, because it
offers the best combj-nation of low project cost and low
vj-sual- impacts to the combined communities of Ketchum and
Sun Val-l-ey. "
0 Thank you for reading the Mayorrs letter.
My question was simply do you stand by your statement
today that the Mayor's letter speaks for itsel-f?
A I be1ieve it does. I just read what was
contained within the letter, correct.
MR. RICHARDSON: Mr. Chairman, given that
Mr. Youngblood's response to this dj-scovery provides that
the Mayor's l-etter speaks f or itsel-f and he has
reaffirmed that assertj-on today, I would move to strike
those portions of Mr. Youngblood's testi-mony, direct
CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
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(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
testimony, in which he is interpreting the Mayor's
l-etter's intent, specifically page lJ, l-ine lJ, through
page 18, line 4, and then the sentence beginning on page
L9, l-ine 4, through line 10. The Company refused to
provide an understanding or a reconcil-iation of the
letter in question stating that it spoke for itsel-f.
Now, in his direct testimony, this witness is presuming
to speak for the Mayor, so I woul-d move to strike those
portj-ons of his testimony.
MR. WALKER: Coul-d we have the citation
again that you wish to strike?
MR. RICHARDSON: Thank
L1, line
you, Mr. Chairman.
page 18, Iine 4,
10.
l-ine 10?
4 with
It would be page
and then page L9,
17, through
through l1neline 4
THE WITNESS: Through
MR. RICHARDSON: Ten.
THE ViITNESS: On page 19 through line 1-0?
MR. RICHARDSON: Oh, excuse me, page 20,
line 4 through l-ine 10. I misspoke, Irm sorry.
COMMISSIONER RAPER: Nothing on page 19?
MR. RICHARDSON: Pardon me?
COMMISSIONER RAPER: Nothing on page
'1 0
L9?
MR. RICHARDSON:Nothing on
beginning on
page
line
That
sentencewou1d be page 20, the
the words, "The City of Sun Valley" ending on line 1025
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CSB REPORT]NG(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
ending with the word "Va11ey" and followed by the
MR. WALKER: Mr. Chairman, I object
that request.
as he has done
this witness is
even though he
question in the
reconcil-iation
for itself.
Certainly, the
in his direct
witness is entitled to do
period
to
simply
and what
for itself
in his
Mayor's letter,
to answer the
for a
Ietter speaks
testj-mony. He 1s
stating and communicating receipt of the letter
it says. The mere fact that the letter speaks
does not preclude a witness from referencing it
direct testimony.
MR. RICHARDSON: Mr. Chairman, the
discovery question asked the Company to reconcile the
statement of the Mayor in which he said that Idaho Power
has decided they need to do this and they're only asking
us to think about how we want it done with the Company's
assertion that the Mayor of Sun Valley is supportive of
the intent and the need for the redundant line. I thlnk
actually interpreting the
denies hls they refused
discovery request asking
by simply stating that the
Wel1,
Chairman. Either the
they can't have
letter
it both ways, Mr.
for itsel-f and it can
or we can interpretstand in the record
speaks
alonecertainly
what the
that the
l-etter means, but
letter speaks for
this witness has testified
itself and then he goes forthI25
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and offers an interpretation of what the l-etter reaIly
means, which is, quite frankly, very different from what
the Mayor instructed the City Council to vote on when 1t
voted on the decision to support the Companyrs
application and which was the impetus for the l-etter in
the first place.
MR. WALKER: Mr. Chairman, that long
explanation really has nothing to do and no nexus to the
request to strike portions of testimony that descrlbe and
introduce the l-etter. In particular, this production
request asks a different question and quotes different
material outside the record from, apparently from, an
audio transcript at Sun Vall-ey and asked to reconcj-l-e
those. The mere statement, which by the way was
completely answered with no objection subsequent, by
Mr. Youngblood answering a different question as to the
letter speaking for itself in relation to other comments
made by the Mayor from a transcript, there's no nexus or
basis to exclude the requested portions of testimony.
There's no confl-icts there.
MR. RICHARDSON: Mr. Chairman, we chose
not to fil-e a motion to compel 1n response to the
Company's dodge of the question in request for production
No. 79, however, the Company provided in direct testimony
through Mr. Youngblood an interpretation of that letter
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
which it refused to provide in response to our discovery,
sor again, I would suggest that the Company is trying to
have it both ways and if the Company wants to dodge
responses to production requests -- properly responding
to production requests, then perhaps we will- be more
litigious in responding to those dodges, but I don't
think the Company should be allowed to have it both ways
here.
COMMISSIONER ANDERSON: I think that the
Chair is going to take a break and I'm going to take the
time to read this and see what my thoughts are a l-ittl-e
bit more generally, so if you have to use the rest rooms
or do any of that, we're going to this is going to be
five minutes.
MR. RfCHARDSON: Thank you, Mr. Chairman.
(Recess. )
COMMISSIONER ANDERSON: Thank you, we'fI
come back in order. Mr. Richardson, the Chair has
determined that your motion to strike will- be noted. The
Chair is not going to strj-ke, but we certainly will give
it the weight that it deserves and I bel-ieve that the
line of questioning, I'm cl-ear on where you were going
with this, I'm very cl-ear. I believe the other
Commlssioners are likewise, so that's my ruling.
MR. RICHARDSON: Thank you, Mr. Chalrman.25
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
I appreciate that ruling, very thoughtful
O BY MR.
have one more question
the likelihood of the
disabled. Do you recal-l- our line
RICHARDSON: Mr. Youngblood, I just
for you and that is relating to
Wood River substation being
of questions on that?
A I do.
MR. RICHARDSON: So Mr. Chairman, may I
approach the wltness?
document made, but
shortly.
(Mr.
MR.
COMMISSIONER ANDERSON: You may.
MR. RICHARDSON: I'm havi-ng copies of this
they'II be hot off the press fairly
Richardson approached the witness. )
ft's a photograph taken
substation in the August
that the substation that
l-ower right-hand corner of
have it marked as Exhibit
RICHARDSON:
cl-ient of the Wood Riverby my
2013
wetre
the photograph and I'd
201 for identification
copj-es brought 1n just
O BY MR.
would you agree
fire, and I'l-l- represent
talking about is in the
Iike to
purposes, and If ll- have additional-
momentarily.
RICHARDSON: So Mr. Youngblood,
COMMISSIONER KJELLANDER: Mr. Richardson,
could you please get near your mic as you prepare to ask
questions?t 25
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CSB REPORTING
(208 ) 890-5198
YOUNGBLOOD (X)
Idaho Power Company
Commissioner.
o
you agree that
disabl-ing the
A
O
A
That question
Mr. Adelman,
o
MR. RICHARDSON: Thank you,
BY MR. RICHARDSON: Mr. Youngblood, would
a catastrophic fire is a possibility for
Wood River substation,' correct?
Based upon this photo?
Based upon your experience.
My experience is not with substations.
may be better answered with Mr. Angel1 or
probably Mr. AngeII.
So as a member of the public in Idaho,
occasion catastrophic
disabl-e electrical- facil-ities?
f have been born and raised in the State
is that
yout re not
fires that
A
aware that we do have on
of Idaho and I am aware that fire wil-l- take out
el-ectrical- f acilities, correct .
O And your substation, the Wood River
substation, is not immune from that, is it?
A Again, based upon this photograph,
what your question is?
O No, based upon your experience, Mr.
Youngblood.
-H.No, it
for 1t.are provr_sr_ons
it' s al-I gravel. Again, the
would not be immune from it. There
f t's gravel, my understanding
question would be betterI
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CSB REPORTING(208) B9o-5198
YOUNGBLOOD (X)
Idaho Power Company
answered by
would be Mr.
o
someone knowledgeable of substatj-ons and that
Angell.
But one doesnrt have to be knowledgeable
of substation engineering to understand that a
catastrophic fire cou1d disable a substation?
A I woul-d disagree. I am not aware
construct of a substation, whatrs all inside of a
of the
substation. An engineer wou1d know
metal-based, whether or not there's
around the facilities that are there
whether or not it's
substantial- area
that
whether or not there are provisions that
mitigate fire. I am not aware of that.
be abl-e to respond to that.
That's all T have
just a note,
exhibit, be
exhibit if
are gravel,
are place to
Mr. Ange11 woul-d
MR. RICHARDSON: Thank you, Mr. Chairman.
COMMISSIONER ANDERSON: Thank you, and
when we do ask a witness to reference an
prepared to provide the witness with the
it's not his own in the future.
We'lI move on now to questioning from
Sierra Club, MS. Nunez.
MS. NUNEZ: Yeah, thank you, Chair.
I 25
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
BY MS. NUNEZ:
o
a couple of
improvement
A
O
testimony, you
committee was
LID approved.
testimony that
instead of 30
CROSS_EXAMINATION
Good morning, Mr. Youngbl-ood.
questions getting us back to the
distri-ct issue.
I just have
local
Okay.
Mr. Adams had brought that up that in your
reference that the community advisory
concerned it would be difficult to get an
In light of PUC Staff Mr. Morrison's
the basellne should be $18.5 million
mil1ion for ca1culating the additional
incremental costs, have you had any conversations with
any of the local- governments or businesses about whether
they would continue to support the Company's proposed
transmission l-ine if there was a renewed requirement for
a LID to cover those additional- incremental costs?
A In response to have
communication with those entities in
Morrison' s transcript?
O Yeah, now that that is
we had
you had any
supportive
support the
response to Mr
additional conversations
on the table, have
with those
entitj-es about whether they woul-d continue to
proposal if there was a LID?I
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
A Not that I'm aware of.
O Have you had any discussions within the
Company about what you would do to recover the costs if
those l-ocal governments did not approve a LID through the
statutory process for enacting a LID?
A The Company maintains that we have an
obligation to serve our customers throughout our servj-ce
terrj-tory with rel-iable, safe power. If there are
incremental- costs assocj-ated with providing that
obligation, those incremental costs would be recovered
from the customers who would benefit from those
incremental- costs, so in this case here, Lf there was a
the Commission determines asdi-f f erential
our base case
community up
that base case, the Company wou1d propose that the
incremental difference or the incremental difference in
the cost woul-d be recovered from the customers that
benefited from that. Did that answer your question?
between what
and an option or provJ-sion that the
there woul-d choose that is different than
0 Half and half, so
what the Company would attempt to
I understand that that's
the Company
those
do, but if the 1oca1
government attempted to pass a LID, you know, went
through the process and the community voted no or for
other reasons the LID was not approved, does
have a backup plan for how they woul-d recoverI25
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (X)
Idaho Power Company
incremental costs?
A Those incremental costs would be allocated
to those customers.
Okay.
The recovery mechanism of that has not yet
been determined.
MS. NUNEZ: Okay, thank you. That's the
only question I have.
COMMISSIONER ANDERSON: Thank you.
CoxCom, Mr. Arkoosh?
MR. ARKOOSH: No questions. Thank you,
Mr. Chair.
COMMISSIONER ANDERSON: Thank you. City
of Ketchum? Mr. Johnson.
MR. JOHNSON: No questions.
COMMISSIONER ANDERSON: No questions.
WeII, I think that's the
MS. HUANG: Staff also has no questions.
COMMISSIONER ANDERSON: Excuse me, and do
we have Laura Midgley here now? Sti1l not here. ff
there is no
u
-H.
objection, the witness
and bear with me fol-ks.
excused.
is my first
Applicant
the Applicant.
may be
ThisExcuse me,
technical-hearing, so I do need to ask the
first the Commlssioners first and then
COMMISSIONER KJELLANDER: Mr. Chairman.I 25
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CSB REPORTTNG(208) 890-s198
YOUNGBLOOD (Com)
Idaho Power Company
EXAMINATION
BY COMMISS]ONER KJELLANDER:
0 Mr. Youngblood, in reference
with those local improvement districts and
through statute, then, to have that process
determine whether or not a l-ocal communj-ty
to
the
go
will
the LID,
ability
forward to
recover
those costs if that LID isn't approved, wouldn't you go
back to the baseline and build overhead? You wouldn't
underground without actual- approval of the LfD, woul-d
you?
A The l-ocal improvement strict or the LfD is
a mechanism by which the Blaine County or the communities
up there could recover the costs from the customers and
pay the Company.
O Correct,correct, I understand what a LID
is. I understand how you get those cost recovery
mechanisms, but if that wasn't approved, wouldn't you go
back to your baseline
assuming the CPCN came
approved, you woul-dn't
sharehol-ders being at
LID not been approved?
A You are
and as you built the project,
together, there was no LID
underground it without the
rlsk for recovering the cost had a
correct that the Company would not
recovery ofbui1d something that would be at risk oft25
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (Com)
Idaho Power Company
those costs from the customers that are impacted by it.
not approved and a CPCN
you Sdy, I think
O SoifaLID
was granted and you needed
would al-1 be overheaded?
what I
were
to build a redundant line, it
A The Company's request for a CPCN is on a
so I woul-d have to wait andparticular option here, and
see what the CPCN that the ,Commissj-on approved, So the
j-ncremental- difference between what the communities may
want to have installed from what the Commission
determines as a base case for the CPCN woul-d be the
difference or the incremental- cost that we would all-ocate
to those communi-ti-es.
I guess what I'm hearing
hear you Sdy, is that would the Company buil,d
something
the CPCN
that is not determined that is not part of
issued by the Commisslon and no, the Commlssion
lsicl would intend to build the line or the option that
the Commission rules a CPCN on. If the communiti-es
wanted something different from that and there was an
j-ncrementa.l- cost, that would be a1l-ocated to those
communities and we would not bui1d it without knowledge
of recovery of that.
COMMISSIONER KJELLANDER: Okay, I think
you got to the answer to the questj-on, then. Thank you.
COMMISSIONER ANDERSON: Commi-ssioner?t 25
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CSB REPORTING
(208 ) 890-5198
YOUNGBLOOD (Com)
Idaho Power Company
EXAMINATION
BY COMMISSIONER RAPER:
O Thanks for coming and testifying, Mr.
Youngblood. There's a l-ot in the record in this case,
but there's a fot that's not in our record thatrs a
matter of public record or whatever because of everything
that's happening in Ketchum and Sun Vall-ey and in Bl-aine
County, and so I'm kind of looking to reconcj-le in my
brain the larger picture here. I understand that Idaho
Power is looking for a redundant l-ine, and in looking at
Dr. Morrison's testimony, Staf f ' s wi-tness, he tal-ks more
about, and there are other parts of the conversatlon that
have been about, putting a temporary line in in order to
build back up the existing line, and I understand that's
not what Idaho Power is asking for here, but has that
consideration been taken into account by Idaho Power
through this process?
Is there something outside of our record
for this case
conversation?
the o1d CPCN
where ]daho Power has had that
And part of my confusi-on in this is we had
and then the relinquishment of the o1d CPCN,
testimony supporting that in that case as
the basis seemed different at the tlme for
and there
wel-l-, and
that than
was
SO
this current request. Sorry, that's a reallyI25
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CSB REPORTING
(208 ) 890-s198
YOUNGBLOOD (Com)
Idaho Power Company
convoluted question. ft comes down to see, this is
where my brain is has the Company considered whether
it woul-d be enough to provide the reliabil-ity that the
Company wants the community to have to build up the
existing line, to replace, repair or whatever, refurbish
the existing l-ine or 1s that just -- was it really just
about a redundant line?
A No, I believe that the Company definitely
has considered what is being suggested by Commission
Staff that it rebullds the existing l-ine. To answer your
question of
whether that
whether or not the Company has determined
is enough to have a rebuilt
the Company still- maj-ntains that it does
reliabll-ity and the risk of serving the
North Va11ey by a single radial l-ine, So
does need to be reconstructed and there
construction techniques to do
to the customers
existing 1ine,
not improve the
customers in the
while that l-ine
woul-d be
that hopefully to mitigate
up there by outage, a
constructed if a redundantto be
the impacts
temporary line may need
line was not available,
removed. There's costs
but then that woul-d have to be
that are associated with that and
those costs woul-d be lost; whereas, a redundant
transmission line would enable the Company to have the
ability to
servi-ce to
reconstruct the existing line and not l-ose
the customers up there and provide increasedI25
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CSB REPORTING(208) 890-s198
YOUNGBLOOD (Com)
Idaho Power Company
reliability. I believe that that testimony is provided
by both Mr. Ange11 in rebuttal and surrebuttal- and by Mr.
Porter in rebuttal testimony.
O One more questionr so we've got
redundancy, relj-abiIity, a l-ot of I'r, words, where does
resiliency fit in? Resi-l-iency came up a 1ot in the
public hearing testimony. In your mind, where does
resiliency fit into the big picture?
A I believe that resiliency is our ability
to quickly restore service to the North Val1ey. If a
redundant line exists, that is almost negligible; in
the service to the North Va11ey customers isother words,
resilient.
CASCS, SO I
do know that
We would have energy there in most of the
don't know if that answers your question.
with regard to
I
there was some questions
redundancy and resj-l-iency and other rrr'r words.
0 Do you see redundancy and resj-liency as
interchangeable ?
A I do not. Redundancy, I think, enabl-es
the system to be more resilient. Redundancy is a means
of having multiple access to a source of energy.
COMMISSIONER RAPER: Thank you, that
answers.
COMMISSIONER ANDERSON: Now that I have
allowed my fel-fow Commissioners to ask their questions,25
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CSB REPORTING(208) 890-s198
I ' 11 go to redirect.
MR. WALKER: No redirect, Mr. Chairman.
COMMISSIONER ANDERSON: Thank you. If
there are no objections, the witness may be excused.
(The witness left the stand. )
MR. WALKER: We'l-l- have the Company cal-I
their next witness.
MR. WALKER: Excuse me, Mr. Chairman, can
the witness be excused from the proceedings or does he
need to stay?
COMMISSIONER ANDERSON: Without objection,
he may be excused
WALKER: Thank you, Mr. Chairman.
RICHARDSON: Mr. Chairman, I wanted to
MR
MR
make copies
this is an
of Exhibit 20L avail-able
opportune time, I can just
COMMISSIONER ANDERSON :
to the parties.
hand that out.
That wou]d be
If
fine.
this belng offered as an
merely demonstrative in
questions ?
(Mr. Richardson distribut.ing documents. )
Chairman isMR. WALKER: Excuse me, Mr.
exhibit lnto evidence or is it
aid of Mr. Richardson's
COMMISSIONER ANDERSON: I believe there
was a request to give it an identifying number as anI25
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CSB REPORTING(208) 890-s198
ANGELL (Di)
Idaho Power Company
exhibit.
MR. WALKER: So f don't believe there's
been any foundation laid to admit this into evidence as
to what it is or what it represents or anything of that
marked as anature. I have no objection if itrs
demonstrative aid in his question.
COMMISSIONER ANDERSON: I think we'11 have
it as a demonstrative aid. Thank you. 301? I believe
the number is 20L.
(Kiki Tidwell Exhibit No. 20L was marked
for identification. )
MR. WALKER: Mr. Chairman, Idaho Power
call-s as its next witness Mr. David Ange1l.
DAVID M. ANGELL,
produced as a witness at the instance
Company, having been first duly sworn
the whole truth, and nothing but the
and testif ied as f ol-lows:
of the Idaho Power
to tel-l the truth,
truth, was examined
D]RECT EXAMINATION
BY MR. WALKER:
O Coul-d you please state your name and spe1l
your l-ast name for the record?t 25
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CSB REPORTING
(208 ) 890-s198
ANGELL (Di)
Idaho Power Company
David M. AngelI,A-n-g-e-1-I.
you employed and in whatAnd by whom are
capaci-ty?
A I am employed by Idaho Power Company. I
am the manager of transmlssion and distribution
planning.
O And are you the same David Ange1l that on
November 8th, 20L6, filed direct testj-mony consisting of
32 pages?
A f am that same.
A And did you also f il-e Exhibits 2, 3, 4, 5,
and 6 along with your
A
o
A Yes,
o Did
rebuttal- testimony
A Yes,
O And
rebuttal?
A
o
14th, 201'7 ,
pages?
A
o
of 10 pages
direct testimony?
did.
also file on June 23rd, 2071,
23 pages?
did.
I
you
of
I
there were no exhibits with your
That is correct.
And Mr. Angell, did you also fil-e on July
surrebuttal testimony consisting of 26
Yes, I did.
And did you also file Exhibit I consisting
as a confidential Exhibit No. 8?I 25
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A Yes, I did. It l-ooks l-ike the surrebuttal-
is 25 pages; is that correct? Oh, a cover sheet plus 25
pages making 26.
O Mr. Ange11, do you have any corrections or
changes to your testimonies or exhibits?
A No, I do not.
O If f were to ask you the questions set out
in your prefiled direct, rebuttal, and surrebuttal-
testimony, would your answers be the same today?
A Yes, they woul-d.
MR. WALKER: Mr. Chairman, I move that the
prefiled direct, rebuttal, and surrebuttal- testimony of
Mr. David Ange1l be spread upon the record as if read and
that his exhibits, Nos. 2, 3, 4,5, 6, and 8, be marked
for identification.
COMMISSIONER ANDERSON: Seeing no
objection, the testimony described along with Exhibits 2,
3, 4, 5, 6, and 8 wil-l- be spread across the record.
(The following prefiled direct, rebuttal,
and surrebuttal testimony of Mr. David Angel is spread
upon the record. )
CSB REPORT]NG
(208 ) 890-s198
ANGELL (DT)
Idaho Power Company
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O. Please state your name and business address.
A. My name is David Ange11. My business address
is 1221, West ldaho Street, Boise, Idaho 83102.
a. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("Idaho
Power" or "Company" ) as the Planning Manager in the
Customer Operations Engineering and Construction
Department.
O. Please describe your educatj-onal background.
A. f graduated in 7984 and 1986 from the
University of Idaho, Moscow, Idaho, receivi-ng a Bachel-or
of Science Degree and Master of Engineering Degree in
El-ectrical- Engineerj-ng, respecti-ve1y. I have provided
el-ectrical engineering instruction for both the
University of Idaho and Boise State University. Most
recently, I instructed power system analysis at Boise
State University during the 2009 spring semester.
O. Pl-ease describe your work experience with Idaho
Power.
A. From 1986 to L996, T was employed by ldaho
Power as an engineer in both communications and
protection systems. fn 1,996, I became the Engineering
Leader of System Protection and Communications. I held
this position until 2004, when I transferred to
Transmission and Distribution Planning. During the fall
of 2006, I accepted
ANGELL, Dr 1
Idaho Power Company
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ANGELL, DI 2
Idaho Power Company
the positions of System Planning Leader and Manager of
Delivery Planning. I have been managing Idaho Power's
interconnected-transmission system, subtransmission, and
distribution planning and strategies sj-nce 2006.
O. What is the purpose of your testimony in this
proceeding?
A. My testimony will provide
description of Idaho Power's need to
transmissi-on llne in the Wood Rlver
a detailed
construct a new
Va1Iey, and provide
Company coming tothethe background and rational-e for
this decision. The Company must
between substations in Hailey and
continuing obligation to provide
service to its customers located
construct f acil-ities
Ketchum to meet its
adequate and reliable
in the Wood River Va1ley
north of East Fork Road, incl-uding the communities of
Ketchum and Sun Va11ey (collectiveIy "North Va11ey").
Today, beyond the continuing requirement to serve the
Wood River Val1ey's growing 1oad, there are two
compelling reasons that now require the construction of
such facilities: (1) the increased relj-ability provided
by a redundant source of energy and (2) the need to
reconstruct the existing and aging 138 kilovol-t ("kV")
radial transmission line without long-term disruption of
service to the North Valley. There has been significant
public outreach, discussion, opposition, as well- as
support to the proposed l-ine
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ANGELL, DI 3
Idaho Power Company
routings. Consequently, the Company is requesting an
order from the Idaho Public Utilities Commission
("Commission" or "IPUC") affirming
convenience and necessity requires
new 138 kV line.
O. PIease
currently exist
that the public
construction of the
I. BACKGROT'ND
describe the area and conditions that
contains the resort
in the North Va11ey area.
A. The North Va11ey
communi-ties of Ketchum and Sun Va1ley and the Sun Va11ey
9,700 customers inski resort. Idaho Power serves over
the North Valley.The peak demand reached 63 megawatts
wj-nter of 2007, wi-th more recent peakduring the
still exceeding 54 MW. The l-ocal population,
of a resort community, increases during the peak
seasons of summer and wj-nter, with hiqh winter
("MW" )
demands
typical
tourist
grid by a single, 12
from the Wood River
4 mile, 138 kV transmission l-ine
substation in Hailey.
7962 with
The
wooden poIes.
residential-
peak demand.
The North Va11ey customers are served by two
substations, one located in Ketchum and the other in the
Elkhorn Va11ey within Sun Valley city limits. These two
substations are connected to the Idaho Power transmissi-on
transmission l-ine was built in
Access to repair the l-ine is impeded by25
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ANGELL, DI 3A
Idaho Power Company
development, rough terraj-n, and
in many areas. The mountainous
access, impedes equipment set-up
aged construction roads
terrain l-imits vehicle
and
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contributes to aval-anche threats. This line's access
limitations may result in extended outages for line
conductor, insulator, or structure failures caused by,
among other things, vandalism, incl-ement weather, wood
decay, woodpecker damage, avalanche, fire, and
mj-cro-burst wind events (col1ectively "Line Events").
Power outages caused by avalanche, fi-re, and other
naturaf events also negatively impact the emergency and
l-ife safety response activities that are crltical- during
these events.
II. COMMUNITY OTITREACH A}ID PI'BLIC PARTICTPATION
O. Has the Company addressed the need for
providing a
North Valley
redundant second transmission source into the
wlth residents of the North Val1ey?
fact, Idaho Power and North ValleyA. Yes. In
residents have partnered together for several- decades to
determine the best approach for meeting the vaI1ey's
electric demands. One example of that partnershj-p
occurred in the mid-1990s. Prior to that partnership,
Idaho Power had received a Certificate of Public
Convenience and Necesslty ( "CPCN" ) from the Commission to
construct a second line between Hailey and Ketchum to
improve reliability
outages. l However,
and reduce the risk of extended
after receiving
public participatlon process, Idaho
opposition durj-ng the
Power agreed to place
ANGELL, DI 4Idaho Power Company
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the
1 tpuc Case No. U-1006-89, Order No. 11315.
ANGELL, DI 4A
Idaho Power Company
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ANGELL, Df 5
Idaho Power Company
project on hold and reanalyze the need at a later date.
The reasons for opposition included the difficulty of
finding an acceptable route for the transmission 1ine,
aesthetic impacts, health and safety concerns, and the
cost of burying part or al-l- of the line.
O. Has the Company continued its outreach and
public participation with its customers in 1ts service
territory and in the Wood River VaIley region?
A. Yes. First al-l-ow me to di-scuss Idaho Power's
process for
substation
involving communlties in the transmissj-on and
planning process. In 2004, Idaho Power
initiated several Community Advisory Committees ("CAC")
and undertook a comprehensive, cooperative transmission
planning exercise with the communitj-es and l-eaders across
its service territory, including the Wood River Valley.
fdaho Power has completed seven CAC processes across its
service terri-tory. These committees were created to
provide a cooperative effort between the Company and the
communities it serves in developing an outl-j-ne for
prioritized improvements and additions to the Company's
transmission and substation infrastructure. Each
committee was created from and reviewed a specific
geographic region. The committees formed to date have
been from the Treasure Valley (three committees), Wood
River VaIley, Magic VaJ-1ey, Eastern Idaho, and West
Central- Mountains (Adams, Boise,
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ANGELL, DI 6
Idaho Power Company
and Va1ley Counties). Each of these committees was
composed of elected offj-ciaIs, jurisdictionaf planners,
civic leaders, business leaders/developers, and
residents. Each committee met on a monthly basis with
each session lasting most of a day. The process included
educational- sessions that began with a bus tour of ldaho
Power facilities. The committees were presented with a
Idaho Power'sview, from production to delivery, of
electrical system, j-ncluding an introduction to el-ectric
generation, substations, transmission, demand-side
management, and electric utility regulation. The
committees then developed a l-ist of goals and siting
criteria that woul-d guide them in their plan development.
The committees were presented with growth statistics and
anticipated l-oad data of their respective areas based on
the planned buil-d-out of their respective communities.
Using the information and educatj-on gained through these
meetings and the knowledge and objectives of local
development, the committees l-aid out proposed
transmission l-ine paths and substation sites. The
committees then determined a preferred plan by consensus,
with some al-ternatives identified. This process of
education and development of the plan took just over a
the result of hundreds of hours ofyear and was
involvement from the communj-ty.I 25
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Idaho Power Company
O. How was community j-nteraction conducted in the
Wood River VaIley?
A. ln 2001, a CAC was convened which developed the
Wood River Va11ey Electrical- PJ-an ("WREP"), a
comprehensive plan for future transmission facilities in
the Wood River VaIley, including the North Va11ey area.
I have provj-ded a copy of the WREP as my Exhibit No. 2.
The WREP is also avail-abl-e publicly on Idaho Power's
website. The 19-member CAC incl-uded regional
transportation and growth planners, various city and
county officlal-s, representatives from the Bureau of Land
Management, the United States Forest Servi-ce, special
interest groups, business l-eaders, and residents. The
CAC met monthly to learn about electrica1
alternatives to meet the va11ey's needs,
the el-ectrical- needs of the
systems, review
and develop a
va11ey goingplan to serve
forward. The
the concfusion
process
of the
developed the WREP, which
move forward with a series
construction of a North Va1Iey
construction of a third 138 kV
O. With regard to the
the construction of a third
was thorough and exhaustive. At
review j-n late 2001, the CAC
recommended that Idaho Power
of projects, including: (1)
project and (2)
fine in the south va1Iey.
WREP's recommendation for
138 kV fine in the south
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A. Idaho Power is not abl-e to develop the third
138 kV transmission line in the south valley due to the
proposed route residing within core sage grouse habitat
as defined in the Idaho Governor's Greater Sage Grouse
Conservation Strategy. Without the ability to site this
third transmission l-ine, Idaho Power initiated the
replacement of the King to Wood River 138 kV transmission
line with new larger conductor and steel- towers. The
construction of this replacement began this summer and
will be approximately halfway compJ-ete in 201-6. The
construction activity is going well- and the replacement
is schedul-ed to be complete next year. This replacement
1ine, in combination wlth the prior modification to the
Midpoint to Wood River 138 kV l-ine, will provide
increased capaclty and reliabil-ity to the Wood River
substation in Hailey.
O. Did Idaho Power continue to meet with the CAC
and/or the North Va11ey community fol-lowing the
development of the WREP?
A. Yes. The Company has more than 100 documented
communications; i.e., meetings and l-etters with city
officials, presentations to committees, open houses,
meetingTs with residents and subdivisions, etc., regarding
potential transmissj-on siting i-n and around the North
VaIIey from 2007 to the present, in addition to the
ANGELL, DI BIdaho Power Company
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numerous other informal di-scussions, phone cal-l-s, and
contacts about this matter.
O. How was the WREP received by the Wood River
Valley residents?
A. In general, support was
to the transmission
expressed for the WREP.
between the Wood River substation and
Improvements system south of the Wood
River substation (to the "King-Wood River" transmisslon
line and the "Sifver" transmission line) received strong
KVsupport. Support
transmission line
Ketchum was mJ-xed,
for the proposed redundant 138
but with a majority in favor. Some
individual-s remained unconvi-nced of the need for a
redundant transmission Ij-ne, or suggested that redundancy
could be provided through other a1ternat j-ves.
0. Based upon feedback from the public
presentations, were any changes made to the origj-nal
WREP?
A. Yes. In 2010 and 2011, the Company reconvened
the CAC to further refine the WREP. At those meetings,
the Company and the CAC discussed detailed sizing pole
heights, reconstruction of existing l-ines, and
a1ternatives to avoid or reduce potential- new visual- and
physical impacts that may be caused by the development of
the proposed redundant 138 kV transmission line between
the Wood Rj-ver substation and Ketchum. Early in 20L1,,25
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the CAC convened to further discuss alternative line
routes for the redundant l-ine,'
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Idaho Power Company
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ANGELL, DI 10
Idaho Power Company
specifically, options for both overhead and underground
installation of the redundant line from the St. Luke's
Hospital area to the Ketchum substation.
The CAC was convened again tn 2072 to fearn new
information about the potential- impact to core sage
grouse habitat that may be caused by recommended
J-mprovements in the Burmah area of the southeast section
of the existing electrlcal system. Because sage grouse
were currently under federal review for potential listing
as an endangered species, Idaho Power informed the CAC
that the recommendations for a third 138 kV transmi-ssion
l-ine in the south valley could
that Idaho Power would instead
not be lmplemented and
undertake the replacement
kV line, ds I have138of the King to Wood River
previously discussed.
a. Were additional-presentations to the public
the refined WREP?
the CAC preferred to have the
from the St. Luke's Hospital area
made to present
A. Yes.Whil-e
redundant l-ine bur.ied
to the Ketchum substatj-on, concern was expressed about
public support for the local-
undergrounding any or aII of
incremental cost of
this section.Therefore,
for both
of the planning
individuals,
subsequent presentations
overhead and underground
Over several- months
team conducted more than
included options
construction.
in
40
2072, members
meetj-ngs withI25
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Idaho Power Company
smal} groups, adjacent neighborhoods, homeowner
assocj-ations, affected property owners, business owners,
and other stakeholders. The purpose of the meetings was
to inform them of the WREP, provide high-1eveJ- cost
estimates for the project, review redundant Ij-ne route
al-ternatives, discuss Local- Improvement District ("Lf D")
boundaries for the col-lection of incremental- costs that
may result from choosing higher-cost underground
alternatives, and to gather input from the public.
Late in 2072, the CAC was reconvened to provide
additional input to the planning team regarding the
format, content, applicable visual aids, and supporting
materials for upcoming public open house events. Three
public open house events were hel-d in December 20L2; one
each in Hailey, Sun Valley, and Ketchum, to present the
refined WREP, and to identify the proposed routes and
high-level cost estimates. Proposed boundaries and
approximate property owner costs for the LID to fund the
incremental local cost for the underground portion of a
redundant line were included. Reaction to the plan was
largely positive; however, some individuals still
questioned the need for the redundant liner ds wel-l- as
the potential- cost to l-ocal- property owners. Some
j-ndividuals expressed opinions that the reliability
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be accompli-shed using renewable energy resources. Strong
opposition was widely expressed for any new overhead
transmission l-ines north of the St. Lukers Hospital area.
O. What was the Company's response to the
suggested alternatives and expressed concerns regarding
the visual- impacts of overhead transmission l-ines?
A. The Company's initial- response to a number of
j-nquiries from the City of Ketchum and the Ketchum Energy
Advisory Committee ("KEAC") was to meet with members of
the KEAC and city representatives in late 20L3 to further
explain the WREP in greater detail-, including the
proposed redundant 1ine, project cost estimates, and
local- incremental costs for the underground sections.
The KEAC was formed in 201-3 to evaluate and provide input
to the City of Ketchum regarding concerns for future
energy security. The discussions incl-uded inquiries from
the KEAC, including a request for a cost/benefit
analysis, consideration of potential al-ternatives to the
redundant line, and opportunities to bury existing
distribution lines in Ketchum i-n coordination with the
proposed redundant line underground construction.
In response to inquiries from both the City of
Ketchum and the KEAC, in late 20L4, the Company invited
representatives from both entities to join the CAC to
investj-gate the possibility of any new a.l-ternatives to
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the proposed redundant line. The "updated" CAC was
convened twice in l-ate 20L4.
O. Were there any new alternatives provided to the
CAC tn 2074?
A. Yes. fn response to some of the expressed
concerns for a redundant transmission Iine, the Company
did introduce to the CAC a potential new al-ternative that
woul-d provide historical load backup power if the
existing transmission l-ine was out of service. The term
"historical-" here meant the current existing Ioad, and
reflected the concept of a distribution alternative to
provide redundant electric service, ot more specifically,
60 MW of capacity, with additional upgrades required for
future growth. The alternative i-ncorporated the use of
an addltional substation and distribution circuits to tie
into the existing
Company noted that
distribution system.
this alternative was
Although the
not a complete
had 1J-mitations,replacement for the
it was developed in
incremental cost for
redundant line and
response to concerns for the
undergrounding a fulIy redundant
transmission line, whj-ch would be recovered from the
Iocal- community.
0. Were other non-conventional- al-ternatives for
providlng redundant el-ectrj-c servj-ce considered?
A
provide
Although new
materials that
representation from Ketchum did
outlined its goals for Ketchum'st25
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Idaho Power Company
energy security, including expanded development of l-ocal
distributed renewable generation and energy conservation,
a viable alternative to the redundant l1ne was not
provided. However, the Company did provide some
additional- high-1eve1 analysis of other al-ternatj-ves for
redundant electric service.
III . MICROGRID AITERNATI\IES TO REDI'IIDA}IT TRJA}ISMISSION
O. Did the Company conduct any analysis of
providing the North Valley with backup electrical supply
from Iocally sited generation?
A. Yes. Individual-s in the Wood River Va11ey have
asked whether loca1 electrj-c generation resources
combined with the distribution grid (i.e., a mi-crogrid)
woul-d be a cost-effective sol-ution to increasing the
reliabil-ity of service to the North Val1ey. This
prompted a CAC member to ask for updated locaI backup
generation information. I have included as Exhibit No. 3
a cover letter and report which provides a summary of
Idaho Powerrs recent work in this area and an updated
analysj-s of mj-crogrid requirements and capability. Al-so
included in Exhibit No. 3 are two revj-sed and updated
appendices, Appendix A and Appendix B, to the October
20L6 report. Idaho Power's preliminary and conceptual
investigation reveals that the cost to provide a 65 MW
microgrid with backup generation for a 24-hour period
ranges from
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approximately $57 million (diesel- engine system) to $955
mil-l-ion (photovoltaic plus battery system) .
O. Please briefly describe the report.
A. The report presents the results of a
preliminary study to provide the northern Wood River
Va1ley customers served by the Ketchum and Elkhorn
substations with backup electrical supply from 1oca1Iy
sj-ted generation. The resources consj-dered in the study
are diesel- reciprocating engine generation, natura1 gas
combustion turbines, photovoltaic plus battery energy
storage systems, geothermal generati-on, and biomass
generation.
The analysis was performed using industry-standard
energy resource simul-ation software, HOMER@, which was
developed by the National- Renewable Energy Laboratory
("NREL"). The capital, operations and maj-ntenance, and
fuel- cost estimates for the resources identified above
were obtained from Lazard's Level-ized Cost of Energy
Analysis Version 9.0.2 Idaho Power al-so compared the
Lazard estimates with pre-engineering budgetary quotes
from several vendors. Additionally, the Idaho National
Laboratory ("fNL"), with more than 1,000 MW of hybrid
power, so1ar, and wind energy systems deployed at
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24 2 Lazard., 2015a. Lazard.'s Levelized Cost of Energy Analysis
Version 9.0,https: / /www.l-azard.com/perspect ive / 1evelj- zed- cost -
of -energy-analysis - 90 / .
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fdaho Power Company
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ANGELL, Dr 76Idaho Power Company
Department of Defense and industry/utility sites around
the world, provided independent technical review and
feedback on the analysis and report.
The analysis demonstrates that the most economical-
way to provide backup electrj-cal- supply from l-ocal
generation (i.e., a microgrid) is by either dlesel-
engines or gas turbines. With respect to the other
resources considered, the study area does not have a
geothermal resource suitable for electrical generation
and biomass generation costs are significantly higher and
the start-up time would be substantially longer than
dj-esel engines or gas turbines. Addltionally, the
biomass generation would require more investigation into
the avail-ability of and cost to extract the Iocal biomass
materlal. Fina11y, the large winter energy requirement
results in a cost prohibitive battery system.
O. What is the Company's concl-usion from this
analys is ?
A.
Company's
All of the
The report provides a high-1evel summary of the
assessment of local backup generation optJ-ons.
options inc1ude higher initial- and ongoing
costs compared to a redundant transmission
l-ine al-ternative.
O. Has the Company revi-ewed any other microgrid
proj ect s ?
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A. Yes. Most recently, the Ketchum City Council
suggested that the Company consider options like the
microgrid project in Borrego Springs, Cal-ifornia. The
Company is famil-j-ar with the project and has reviewed the
final report prepared for the California Energy
Commission ("CEC") by San Diego Gas & Electric ("SDG&E").
The project was a microgrid demonstration project that
focused on the design, installation, and operation of a
communj-ty scal-e "proof-of-concept" microgrid. The
microgrid was an existing utility circuit that had a peak
Ioad of 4.6 MW serving 615 customers j-n Borrego Springs,
Cal-ifornia. The project was funded through a U.S.
Department of Energy ("DOE") and CEC grant and cost share
provided by SDG&E and other project team members. The
project's partners included Lockheed Martin, IBM,
Advanced Energy Storage, Horizon Energy, Oracle,
Motorola, Pacific No::thwest National- Laboratories, and
the University of Cal-ifornia San Diego. The DOE
supported the project with $7.5 mil-l-ion of federal-
funding, with additional- funding coming from SDG&E ($4.1
mil-l-ion) , CEC ($2 . I mil-l-ion) , and other partners ($0 . I
million) . Upon completion, the total- mj-crogrid instal-l-ed
capacity was expected to be 4 MW, with the main
technologies being two 1.8 MW diesel generators, a large
500 kilowatt ("kW")/L500 kilowatt-hour ("kwh") battery at
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the substation, three smal-1er 50 kWh batteries, six 4
kw/8
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kWh home energy storage units, about 700 kW of rooftop
sol-ar photovoltaics, and 1,25 resj-dential home area
network systems.
The final report provided some key lessons learned
from the microgrid demonstration project, stating that
the project proved to be challenging due to the
complexity of integrating new systems into the
distribution network that could j-mpact customers,
reliance on other projects for integration, the use of
newly emerging technologies and systems, and
environmental requirements .
O. What has Idaho Power concluded from 1ts
investigation into alternatives for the redundant
transmission l-ine?
A. Many of the alternative options suggested by
the KEAC or CAC are interesting and innovative; however,
they are technologies that are either cost prohibitive or
just not viabl-e today. The Borrego Springs mlcrogrid
demonstration project is a good example of this. While
the project was successful in provi-ding all of the
el-ectrj-city delivered to the Borrego Springs community
during a five and a hal-f hour preplanned operation, the
Company does not believe that this wou1d be a viabl-e
cost-effective option for the North VaIley today. A
simple extrapolation of the project costs would suggest
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that if a 4.0 MW microgrid cost $15 million at Borrego
Springs, then a 60 MW microgrid for
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Idaho Power Company
the North Val1ey would cost $225 miIIj-on, or more
importantly, for the 9,000 customers in the North Va11ey,
woul-d cost approximately $25,000 each. These al-ternative
technol-ogies are just not cost-effectj-ve today, would
only provide electric backup for a relatively short
period of time, and woul-d still- not eliminate the need
for the redundant transmission system.
IV. PT'RPOSE AtiID NEED
a. When
construction of
in a particular
A. Idaho Power generally initiates and constructs
source and transformer when aa second transmission
substatlon peak load is projected to exceed 40 MW.
Recent examples include the additions of second
transmission lines and transformers at the Victory
substation south of Boise and the McCal-l substation in
woul-d Idaho Power normally consider the
additional facil-ities to serve customers
area?
McCal-1, Idaho. Idaho Power
second transmission proj ect
. Thewhich peaks at
represents the
Power's service
transmission line. The Ketchum
is also moving forward with a
in the Eagle and Star area,
area north of Hailey1I MW
second J-argest customer base in Idaho
territory served by
and
only a single
Elkhorn substations'
peak l-oad of about 60 MW, coupled with the winter tourj-sm
population
need for a
in the
second
North Va11ey, strongly supports thetransmission line.
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ANGELL, Dr 20Idaho Power Company
O. At what time of year would a significant risk
of an outage on the current transmission l-ine be most
likeIy to occur?
A. The most significant risk of an outage on the
current single 138 kV transmission l-ine and the resulting
economic j-mpact would occur during the winter season when
the el-ectric demand and tourism activity are at their
highest. Deep snow and steep terrain can make it very
difficul-t to access the susceptible sectj-ons of the
existing transmissj-on l-ine, resulti-ng in sustained
outages (defined as an interruption that lasts more than
five minutes). An extended outage coul-d last multiple
days and be catastrophic, not only from the economic l-oss
of the area, but the additional- damage that may be caused
by water pipes freezing. Summers are not immune from
risk either, wj-th the potentj-aI for a fire to take out
the existing l1ne, affecting the ability to pump gas or
water, and resulting in economic loss.
O. Has Idaho Power estimated the potentj-al- for
future sustained outages in the North Va1Iey?
A. Yes. Historical-ly, this particular line has
had a rel-atively good service record for rel-iability.
Thj-s was one of the reasons that the previously issued
CPCN was withdrawn in 1995. However, this line, built in
L962, has not aged well
reconstruction.
and now requires completeI25
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Idaho Power estimates that without any significant
changes to the existing North Valley transmission 1ine,
the expectation coul-d be that the current configuration
will result in an average duration of sustained outages
of more than 209 minutes per year.
O. How has the existing transmission l-ine
performed?
A. The l-ine has performed better than average for
the 138 kV cl-ass of transmisslon lines. One performance
measure is the occurrence of unplanned sustained outages.
The existj-ng Hailey to Ketchum 138 kV line has a
frequency of !.23 unplanned sustai-ned outage events per
year per 100 mil-es. Idaho Power's system-wide average
for 138 kV lines is 1.89 events per year per 100 miles.
However, the l-ine j-s showing its age. For example, the
lj-ne was de-energized for seven hours and 45 minutes in
2015 to replace poles that were damaged by woodpeckers.
O. Has the Company considered the reconstructj-on
of the existing line as
and improve the system
A. Yes, the
would help mitigate
wlthout considerj-ng
one option
reliability
reconstructi-on
outages in the
the need for a
to mitigate outages
in the North Va1ley?
of the existing line
North Va11ey. Even
redundant transmission
existing
The
l-ine, Idaho Power has determined that the
transmission l-ine requires reconstruction.25
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reconstruction would not ellminate the need for a
redundant transmission line. Without another source of
energy into the va11ey, the reconstruction of the
existing radj-al-
challenges.
O. What
transmission line involve?
A. The reconstruction
involves replaci-ng the wood
structures in approximately
Iine would have its own significant
would the reconstruction of the existing
of the existing line
structures with steel
the same l-ocati-ons and
replacing the existing conductor. During this
reconstruction, it is esti-mated that 51 out of 93
structure replacements would requj-re as many as 40
eight-hour line outagesr or 20 assuming the use of two
construction crews. Furthermore, it is estimated that
the replacement of the line conductor would require a six
to 72 week continuous outage. Replacing the other 35
structures whil-e the line 1s energized woul-d requj-re much
Iarger construction equipment pads that produce
significant environmental- and aesthetic impacts,
particularly on hillsides.
O. What is the alternatj-ve to replacing the
existing line while energized?
A. Considering all the impacts descrj-bed above,
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energized is not feasibl-e. A temporary line to the
Ketchum substation would be required to serve the
customers of the
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Ketchum and El-khorn substations during the reconstructj-on
of the existing line. The temporary line would be placed
in road right-of-wdy, mostly along Highway 75, to
minimize private property impact and right-of-way costs.
The temporary line would almost assuredly be deemed a
visual impact by many North ValIey customers. Following
the completion of the reconstruction, the majority of
temporary l-ine material-s (poIes and insufators) would be
salvaged; however, the conductor cannot be salvaged.
O. Does construction of the redundant 138 kV line
el-iminate or change the reconstruction of the existing
Iine ?
A. Construction of the redundant 138 kV line does
not el-iminate the need to reconstruct the existing line.
Thls must be done regardless. However, with the
construction of the redundant source the reconstruction
of the existing l-ine can be done with l-ittle to no
disruption of service. The new redundant l-ine can meet
the North Valley's electrical- needs during the ti-me when
the existing line is taken out of service for
reconstruction, thus saving the l-ost investment in the
temporary line that would otherwise have been required
for reconstruction.
O. What is the Company's typical construction
configuration r or standard practice, for providing
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redundant electrlc service to an area in need of
redundancy
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Idaho Power Company
in order to reduce sustained outages and continue
providing reliabl-e electric service?
A. The Companyrs standard practice to reduce the
l-ikelihood of sustained outages would be to construct
multiple overhead transmission lines (a redundant
transmissj-on source) or to implement distribution
circuits with tie switches in order to continue providing
customers with reliable el-ectric service.
O. What are the challenges to bulldlng redundant
el-ectric service in the North Va11ey area?
A. The North ValIey exhibits several- transmj-ssion
si-ting obstacles for overhead access to the existing
Ketchum substatj-on. The North Valley is congested due to
numerous resj-dences and businesses sited in a valley l-ess
than one mil-e wide with mountains of steep slope and
narrow roadways. This woul-d force an overhead
transmj-ssion l-ine either through the downtown district or
over the top of Dollar Mountain, spanning existing homes
near the substation in order to reach the existing
Ketchum substation. The va11ey has ordinances
restricting certain development. For example, because of
these steep slopes and for aesthetic reasons, Blaine
County has an ordinance limiting the deveJ-opment along
the mountains (Mountain Overlay District). The cities of
Ketchum and Sun Va11ey prefer new electrical- facilitiesbe located underground,I 25
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Idaho Power Company
and the communi-ties
visual impacts from
representatives have
would not be al-lowed
are adamantly against additional
overhead l-ines. Idaho Power
been advised that new overhead lines
in Ketchum and Sun Va11ey.
a number ofO. Has
transmission
the Company eval-uated
or distribution routes and alternatives to
provide redundant el-ectric service to the North Val1ey?
A. Yes. The Company has evaluated four
construction configuration alternatives for providing
redundant electric service to the North VaIIey,
identified as: (1) Overhead Transmission, (2)
Underground Transmission, (3) Overhead Distribution, and
(4) Underground Dj-stribution.
V. REDI'IIDA}IT EI,ECTRICAL SERVICE OPTIONS
O. Please describe the four redundant electric
in greater detail.service configurations
A. A11 four of
routes begin with the
as the "Common Route. "
transmission l-ine that
the redundant el-ectric service
same basic configuration, defined
The Common Route is a 138 kV
would be constructed overhead from
the Wood River Transmission east to Buttercup
and Highway 75 to
Road. From this
Road, then north
approximately the
point north, each
differ.
along the
area near
Station,
bike path
Owl- Rock
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ANGELL, Dr 26
fdaho Power Company
Pl-ease see my Exhibit No. 4 for an overview map that
shows the Common Route
1. Overhead Transmission
As discussed above, because of
obstacl-es for overhead access to the
substation, an overhead transmission
forced to run either through the
of Dollar Mountain.over the top
Transmission-Do1lar Mountain route
Common Route along Highway 75 and
El-khorn Road. At that point, the
several- siting
exi-sting Ketchum
line route woul-d be
downtown distrlct or
The Overhead
would begin with the
continue north to
route woul-d follow
El-khorn Road to Larry's Lane (private road) near the
existing El-khorn substation, where the existing
transmission l-ine crosses. The remainder of the route
woul-d be doub1e circuit to the Ketchum substation,
requiring the existing structures to be replaced with
structures that can accommodate both transmission
circuits. Please see my Exhibit No. 4.
The Overhead Transmission-Downtown District route
wou1d al-so begin with the Common
and continue north along Highway
Ketchum to Gem Street. The route
through downtown Ketchum, taking
l-eft on Leadvill-e Avenue, a right
on East Avenue South, a right on
a right on
on River Street, a left
1st Street, a l-eft on
Route along
15 into the
then winds
Highway 15
City of
its way
Gem Street, a
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Wal-nut Avenue, a right on 2nd Street, a left on Spruce
and, f inalJ-y,Avenue,
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ANGELL, DI 21
Idaho Power Company
a right on Sun Val-l-ey Road. The route then foll-ows Sun
Val1ey Road to the Ketchum substation. Please see my
Exhibit No. 4.
2. Underground Transmission.
The Underground Transmission construction
configuration woul-d include the Common Route along
Highway 75 to one of three possible overhead-to-
underground transition points between Owl- Rock Road and
El-khorn Road, at which point the transmissi-on line woul-d
be constructed underground and proceed along the highway
and in road rights-of-way to the Ketchum substati-on. The
three potential transition points are: (1) just before
entering the City of Ketchum, near the intersectj-on of
Elkhorn Road and Highway 75, (2) further south, near the
intersection of Hospital Drive and Highway 75, and (3)
prior to the hospital, near the intersection of Owl- Rock
Road and Highway 75. Each of these al-ternative routes
woul-d provide an independent and fulIy redundant
transmission source. Please see my Exhibit No. 5 for a
map of the Underground Transmission construction
configuration showing the three transition poJ-nt options.
3. Overhead Distribution.
The Overhead Distribution construction configuration
woul-d include the Common Route to a new substation site
on the west side of Highway 75 south of Owl Rock Road.I 25
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Idaho Power Company
This option woul-d j-nclude a new substation with 2 x 44.8
MVA 1,38/L2.5 kV transformers, two 4-bay metalclad
sectj-ons, five feeder getaways, a control building, 10
foot decorative walIs, and sound barriers around the
transformers. Five overhead distribution circuits would
connect with
distribution
and optical
Control- and
the existing Ketchum and El-khorn
circuits. Elght sets of padmount
fiber from the new substation for
substation
switchgear
Supervi-sory
wil-l- beData Acquisition
effectuate the
(SCADA) control
installed to l-oad transfers during outages
of any transmission line or substation. Unl-ike the
Underground Transmj-ssion option, this option (and the
next) only provides 60 MW of additional service capacity
on five distribution circuits. Additional ci-rcuits would
need to be constructed if the area peak load increases.
Please see my Exhibit No. 6 for a map showing the
Overhead Distribution construction configuration.
4. Underground Distribution.
The Underground Distribution construction
configuration would also include the Common Route to a
new substation slte on the west side of Highway 15 south
of OwI Rock Road. From t.his point oD, the option is
substantially the same as the Overhead Dj-stribution
option with the 1,2.5 kV distribution circuits instal-l-ed
underground requiring boring, asphalt, and landscape
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O. Has the Company concluded that al-l- of these
alternatives and routes provide viab1e options for
redundant electric service to the North Va11ey?
A. No. Vrlhil-e the Overhead Transmi-ssion
construction configuration may reflect the Company's
typical construction configuration, or standard practice,
for providing redundant electric service to an area in
need of redundancy, the Company has concluded that the
Overhead Transmission construction conflguration is not a
viable option based on the transmi-ssj-on siting obstacl-es
described above. With regard to the Dollar Mountain
overhead option, the North Va1ley section of an overhead
Iine wou1d be limited to a doub1e circuit option on a
conrmon tower configuration from the Elkhorn substation to
the Ketchum substation across the top of DoIlar Mountain.
Thls conrmon tower construction has a hlgh probability of
simul-taneous loss of both transmission circuits and North
Valley customer outages for the Line Events, thereby not
truly providing redundant rel-iabl-e service and not
meeting the requlred purpose and need for a redundant
Ii-ne. Additionally, condemnation of private property may
be required to enter the Ketchum substation overhead from
Dollar Mountaj-n. Fina1ly, the Company believes that
North Va11ey customers would likeJ-y strongly oppose this
option due to the visual- impacts.
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Idaho Power Company
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O. Does the Overhead Transmissj-on construction
configuration through the downtown district of Ketchum
provide a viable option?
A. No. While the Overhead Transmission route
through the Ketchum downtown district may be
theoretically possible to construct from an engineering
perspective, it has several insurmountabl-e problems.
Eirst, it would be vigorously opposed and Iikely not
permitted by the City of Ketchum. The Downtown District
overhead option has additional challenges, incl-uding the
fact that the City of Ketchum consists of a grid of
streets, sidewalks, and zero setback buildings that
provides l-1tt1e to no room for transmissj-on tower
structures and line clearances. Options that exist for
construction of overhead transmission lncl-ude placing the
poles in the sidewalks, the edge of streets, overhanging
the wires over the streets, utiliz:nq side streets, and
constructing tall- enough structures to span the wires
over the tops of buildings. Because of the very tight
geographical- constraints, this option woul-d 1ike1y be
dependent upon and require significant condemnation of
private property in order to pass through downtown
Ketchum with an overhead l-ine to the Ketchum substation.
Ultimately, the Company has concluded that neither
of the two possibl-e route options for an Overhead
ANGELL, DI 30
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Transmission construction configuration provides a viab1e
solution for redundant el-ectric service to the North
ValIey.
0. Do the three remaining construction
configuratj-ons provide potential viable sol-utions for
redundant electric service to the North Va11ey?
A. Yes. The three remaj-ning construction
configurations would all provide viab1e sol-utions for
redundant electric servj-ce to the North Val1ey, each with
their own set of costs and varying degrees of benefits
and detriments. The remaj-ning three construction
confj-gurations: (1) Underground Transmission, (2)
Overhead Distribution, and (3) Underground Distribution
are the three construction configurations that were
provided to Company witness Ryan Adel-man for further
anal-ysis and evaluation.
O. Does this conclude your testimony?
A. Yes.
ANGELL, DI 31
Idaho Power Company
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Idaho Power Company
O. Please state your name and business address.
A. My name is David Ange11. My business address
is L227 West Idaho Street, Boise, Idaho 83102.
O. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("Idaho
Power" or "Company" ) as the Transmission and Distribution
Planning Manager.
O. What j-s the purpose of your rebuttal- testimony
in this proceedlng?
A. Idaho Public Utilities Commisslon Staff
("Staff") witness, Michael Morrison, and Idaho Sierra
Cl-ub witness, Michael Heckler, both conclude that a
redundant transmission Iine in the North Va1Iey is not
needed to meet the Companyrs obligation to reliably serve
customers. The purpose of my rebutta1 testimony is to
describe how Idaho Power pIans, designs, bui1ds, and
operates its transmission and distribution system
incorporating concepts and requirements for redundancy in
order to meet its obligation to reliably serve retail-
customers. I wil-l- al-so respond to several items raj-sed
by Mr. Heckler in his direct testimony.
I . TRA}ISMISSION AT{D DISTRIBUTION PI,A}INING
A}ID DESIGN STA}iIDARDS
O. How does
distribution system
the Company plan the transmission and
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Idaho Power Company
A. Transmi-ssion and distribution planning is
in a reliablefocused on supplying sufficient capacity
and cost-effective manner.
The capacity of the system is sized in a simi-Iar way
as transportation systems, such that there are large
capacity components that provide transport for generation
to large geographical- areas, where it then connects to a
network of smaller capacity components, ultimately
del-ivering energy to the end-use retail- customer. An
example of this is the high capacity 230, 345, and 500
kil-ovolt ('rkVrr) transmission system that connects the
generation source to hub substations located near Jerome,
Eden, and Hagerman in the Magic Va11ey. The voltage is
reduced through transformation at each of these
substations to 138 kV. The 138 kV transmissi-on l-ines
distribute power to distribution substations within the
Magic and Wood River Va11eys. Distribution substations
further reduce the voltage to 12.47 and 34. 5 kV for
distribution withi-n local- communities to the end-use
customer.
The capacity requirements are determined through
analysis of historical- customer peak demand and
projections of future demand, taking into account both
energy efficiency reductions and growth in industrial,
commerci-al, and residential- customers. Historical- demandI25
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is captured and adjusted to account for extreme
temperature events to
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ANGELL, REB 2A
Idaho Power Company
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ensure sufficient capacity in the system to meet the peak
demand during these i-nfrequent weather conditions.
O. When are capacity additions made to the
transmission and distribution system?
A. The Company's planning engineers identify
capacity additions five years j-n advance of the
forecasted need. Demand and customer additions are
closely tracked during this period to optimize the timing
of the capacity addition.
O. Does the Company involve the local- community in
the planning process?
A. As described in my direct testimony, the
Company invofves the local- communj-ty in planning the
location of the facil-ities required to meet future
el-ectrical demand. El-ectric plans are developed with the
communities and are publicly available on the Company's
website. The electric plans identify specific
transmission and substation projects along with their
anticipated in-service date.
0. How is transmission, distribution, and
substatj-on reliability planned and designed for in the
system?
A. Reliability is consj-dered when planning the
capaci-ty additions, and is based upon fundamental
concepts of redundancy and not having a}l of your eggs in
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Idaho Power Company
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ANGELL, REB 4
Idaho Power Company
one basket. The system is designed in such a way that it
can and does evofve and grow as it expands with the
growth and change of the customers and l-oad it serves.
Reliability is greatly improved and enhanced by the
ability to limit outages to smal-l-er segments of customer
populations and by having more than one source of energy
availabl-e that can take over when the primary source 1s
interrupted. The Company has established design
standards, or criteria for capaci-ty addltions to the
system and the design of necessary upgrades or additions
to transmission and distribution lines, and substatj-ons
that enhance rel-iabil-ity and incorporate these concepts
of adequate and rel-iable servj-ce balanced with cost.
A new substation is typically energized with a
single transmj-ssion line, single transformer, and two or
three distribution circuits that could serve up to 30
megawatts
circuit is
("MW'r) of customer l-oad. Each distribution
configured to serve up to 10 MW of customer
l-oad to limit the number of customers impacted by a
circuit outage. When feasibl-e, tie switches are
installed between ci-rcuits to aIlow customer l-oad
transfers to other circuits when an outage occurs on the
for a substation that isprimary cj-rcuit. As load grows
energized with a single transmission line, two things
capacity addition will be requiredhappen: eventually, a
to serve growing load;25
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ANGELL, REB 5
Idaho Power Company
and the risk and consequences associated with service
disruption
peak load
and potential long-term outage increase. Once
at a single substation is projected to exceed
40 MW, Idaho
transmission
necessary
u
referenced
reliability
Can you give
fundamental-
Power planning standards require a second
source and transformer to provide the
the number and amount of
transformer outage to 40
al-so limits distribution
and servi-ce to customers.
other examples of how the
principles of mitigating
MW. Additionally, the Company
substations to 100 MW of l-oad
and redundancy are
planned, designed,
A. Yes. The
a part of how Idaho Power's
exposure
system is
and operated?
largest distribution
Company has sel-ected 44.8 MVA as the
substation transformer to be
installed. A maximum of four distribution circuits are
connected to a transformer. This configuration l-imits
customer load impacted by a
service before a new substation is required.
O. What is the transmissj-on configuration for a
distribution substation?
A. The transmission confj-guration depends on the
l-oad service 1evel of the substation. As stated, the
Company standard is to serve up to 40 MW from a single
transmj-ssion l-1ne. Once the planning engineers forecast
the substation load will exceed 40 MW, they propose thea25
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Idaho Power Company
addition of a second transmission line and specify how
that line
o.
Company' s
criteria ?
A.
generally
source and
will connect
How does the
transmission
As stated in
into the transmission network.
North Va1Iey fit within the
and distribution planning
my direct testJ-mony, Idaho Power
initiates and constructs a second transmission
transformer when a substation peak l-oad is
projected to exceed 40 MW pursuant to prudent utility
planning and design criteria. Recent examples inc1ude
the additions of second transmission lines and
transformers at the Victory substation south of Boise and
the McCall substation in McCal-l-, Idaho. Idaho Power is
also moving forward with a second transmissj-on project in
the Eagle and Star area, which peaks at 17 MW. The area
north of Hailey, served by the Ketchum and E1khorn
substations, represents the second largest customer base
in Idaho Power's service territory served by only a
single transmission line. The Ketchum and Elkhorn
substations' peak load of about 60 MW, coupled with the
winter tourism population in the North Valley and the
mountainous terraj-n with difficult access to the existing
line, strongly supports the need for a second
transmission line.
O. Are there other similarly situated areas ofo25
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customers as that of the North Va11ey served by a
redundant transmi-ssion source?
ANGELL, REB 6AIdaho Power Company
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Idaho Power Company
A. Yes. The proposed transmission configuration
for the North Va11ey is si-milar to that serving McCall
and Salmon, two remote communities like the north Wood
River Va11ey. The McCaIl substation is served by two 138
kV transmission lines that connect to the Starkey
substation. The Sal-mon area substations are served by
two 59 kV transmission lines that are sourced from the
Agency Creek substation.
There are many short 138 kV transmission l-ines
serving substations in the Treasure Valley, Magic Va11ey,
and Pocatello service areas with reliability performance
that matches or exceeds the Wood River-Ketchum l-ine. fn
al-l- cases, the Company plans the system for the addition
of a second transmj-ssion circuit when any substation peak
demand is forecasted to exceed 40 MW to allow for planned
and unplanned outages of transmission and substatj-on
facil-ities.
O. Is it typical for utilities to establish
redundant transmission criteria for distribution
substations ?
A. Yes. Each utility establi-shes planning
crlteria that include redundant transmission
configurations for distribution substations. The three
Northwest investor-owned util-ities that serve customers
in Idaho al-l- have
redundant service
reliability criterj-a regarding
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is consistent with Idaho Powerrs criteria. Idaho Power
ini-tiates and constructs a second transmission source and
transformer when peak load is projected to exceed 40 MW.
Avista plans for a second transmission line at a
threshold of 75 MW, but is currentl-y reducing that
threshol-d. Rocky Mountain Power does not have a specific
load 1evel trigger but eval-uates peak l-oad with outage
probability and durati-on, where the outage duration is
based on an estimated repair time considering terrain and
access difficulty. Northwestern Energy adds a second
transmission line when the substation demand exceeds 20
MW.
0. May utilities establ-ish their own criteria for
transmission rel-iability?
A. The Federal- Energy Regulatory Commissj-on
("FERC") has jurlsdiction over the rel-iability of the
bulk-power system. Utilities must design, construct, and
operate their systems consistent with EERC requirements,
and thus utilities estab1ish criteria designed to meet
the FERC reliabil-ity requj-rements. Utility criteria may
vary, as referenced above, but is bounded by the
standards established by FERC. FERC regulation of
reliability standards was establ-ished in the Energy
Policy Act of 2005 following the 2003 eastern
interconnection blackout. The 2005 Act requlred FERC to
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Idaho Power Company
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certify an El-ectric
whose purpose is to
Reliabil-ity Organization ("ERO"),
establish and
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enforce reliabil-ity standards. FERC certified the North
American El-ectric Reliabil-ity Corporation ("NERC" ) as the
ERO.
O. Are there standards for planning the
transmission system with respect to transmission line
outages ?
A. Yes. The NERC Transmission System Planning
Performance Requirements Reliabil-ity Standard, approved
by EERC on October 17, 2013, addresses how transmission
planning engineers must plan the bulk-power system so
that it meets performance requirements over a broad
spectrum of system operating conditions and following a
wj-de range of probable transmission facility outages.
One objective of the standard is for the transmission
planning engineers to design the system to minimize the
l-ikel-ihood and magnitude of firm transmission service
interruptions r or non-consequential l-oad loss, following
a facility outage due to a short circuj-t within a Iine,
transformer, or generator.
O. Is there a limit to the planned amount of
non-consequential load loss allowed for a single facility
outage due to a short circuit within a Iine, transformer,
or generator?
A. Yes. NERC has established reliability
standards for the non-consequential l-oad loss for the
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l-oss of a single transmission line and for the l-oss of
two
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Idaho Power Company
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Idaho Power Company
transmission lines. The standards account for the
probability of an event. Because the l-oss of two
transmission l-ines at the same time has a much l-ower
probability than the l-oss of one transmission l-ine, the
NERC reliability standards al-Iow for unl-imited non-
consequential- l-oad l-oss for the l-oss of two transmission
lines. The upper l-imit for a single transmission line is
a non-consequential- load l-oss of 75 MW. The 75 MW limit
to non-consequenti-al- l-oad l-oss establishes a nationaJ-1y
agreed upon upper bound to the amount of load to be at
risk for a single facility outage. The Company's
approach of limiting the customer load served by a single
transformer to 40 MW, aJ-ong with planning for conversion
of substations from radial- to network connectivity with
redundant servj-ce, is a prudent utility practice designed
to meet and exceed this national- standard.
O. Staff witness Michael Morrison ultimately
concludes that there is no demonstrated need for a
redundant Line, essentially arguing that the
its
existing
own and thatradial l-ine is sufficiently reliabl-e on
it is too expensive to provide redundant facilities. Is
this consistent with prudent utility practJ-ces of system
design and the Level of rel-iabil-ity expected of the
Company in its provision of essential service to the
public?I
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Idaho Power Company
A. No, Idaho Power designs its system to meet
certaj-n rel-iabil-ity and service quality standards that
are consistent with other utillties as wel-l as national
standards. When these criteria for upgrades or additions
are met, all of which are met by the current situation j-n
the North Va11ey, redundant servj-ce is provided to reduce
the risk, cost, and potential damage to the public from
interruption of service or long-term outage. The North
Valley area has grown to such a size, is relatively
remote with difficult to access facilities, and has a
substantial seasonal resort economy that the risk of harm
from a potential long-term outage and the potential
catastrophic effects of a long-term outage during extreme
wi-nter conditions when North Va11ey electric load peaks
is too great to be served by a single, radial feed-no
matter how rel-iable that single transmission line may
have been in the past.
The redundant transmission source is the most
cost-effective means of providing the required
rel-iability improvements and mitigation of potentialty
damaging outages in the North Val1ey. Idaho Power
evaluated several other sources of alternative or
additional- generatj-on for the North Va11ey, which I wil-1
address next in my response to several of Mr. Heckl-er's
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ANGELL, REB T2
Idaho Power Company
II. RESPONSE TO IDAIIO SIERRA CLUB
O. Idaho Sierra Cl-ub's witness, Mr. Michael-
Heckler, advocates that other sol-utions besides that of
building a second transmission l-ine would be better and
provide more cost-ef f ective rel-iabil-ity solutions.
Heckler Direct, p. 2. He states that the Company has
errors and misrepresentations in the terminology used
with regard to "rel-iability" "redundancy" and "proximity"
stati-ng that "redundancy is not the need itself.
Rel-iab1e servi-ce is the need." Heckler Direct, p. 5. Is
redundant transmission line, ot redundancy,the proposed
the need in and of ltself as Mr Heck1er has portrayed?
is to provide adequate
in a cost-effective
A. Not exactly. The need
and re]iable electrical service
manner to the public, including essential services. As
stated, a fundamental- design principle in the electric
utility industry is to meet reliability through providing
redundancy and spreading exposure across multiple small-er
facil-ities rather than being completely reliant on a
single facility. In my di-rect testimony on page 2, l-ine
13, I address the need as the "obligation to provide
adequate and rel-iabl-e servj-ce" and I then further clarify
the need on l-ines 20 and 21 as "increased reliability
provlded by a redundant source of energy. " These
statements differentj-ate that the need is for redundancy
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supply in order to provide rel-iabl-e service. The
proposed transmissj-on line is not required to address a
forecasted peak demand beyond the capacity of the
existing transmission Lj-ne. However, Mr. Heckler has
identified one of the larger questions in this case that
the Idaho Publ-ic Utilities Commission must determine:
Does the Company's obligation to provide reliabl-e service
to the public 1n the North Va11ey require a second
transmission line as a source of energy in order to
mitigate the risk posed by an extended outage of the
current radial service to public safety, essential
services, businesses, and property damage. This issue is
discussed further in Idaho Power's rebuttal- testimony of
N. Vern Porter. No matter how good the rel-iabil-ity is of
the existing line, the North Val1ey remains exposed to
the risks associated with long-term outage to that single
line unless and until- a redundant sourcer or second line,
j-s avail-abl-e. NERC reliability standards embody the
concept of redundant service and elimination of radial-
service as required reliability improvements.
The Company has an obligation to provide service
that meets customers' demand as it may vary throughout
each day and season. As stated above, the Company also
plans for j-ncreasing rel-iabil-ity of service when the
aggregate peak demand exceeds 40 MW. The Company has
eval-uated
ANGELL, REB 13
fdaho Power Company
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multiple options to supply the peak demand as provided in
my direct testimony, and a second transmlssion source is
the most cost-effective rel-iabil-ity solution for the risk
exposure in the North Va11ey.
O. Mr. Heckler then addresses "redundancy" and
"proximity" concl-uding that "the proposed redundant line
will not provide an independent source of energy as the
Company purports." Is this correct?
A. No. The "proximity" issue raised by Mr.
Heckler refers to my direct testimony on page 29 where I
describe a double circuit option on a common tower
configuration from the El-khorn substation to the Ketchum
Heckler then attempts
circuit/common tower
top
to equate this double
substation across the of DoIlar Mountain. Mr.
conf j-guration
words:
with the proposed l-ine
route where, in his
The Company's proposed route is not free from thestated problem of having two l1nes being in closeproximity of each other. The proposed l-ine woul-d
cross the existing WDRI-KCHM 11ne wlthin a quartermile of where both lines l-eave their common sourceat the WDRI substation. Moreover, there are never
more than a few hundred yards separating the twol-ines for the first few mi-Ies of their routes northof WDRI.
Heck.l-er Direct, p. 7.
First of al-l-, it is not true that the proposed line and
the existing line cross. They do not cross, nor dot25
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Idaho Power Company
they share
prohibited
beyond a common tower confj-guration.
option on a common tower configuration
conimon towers. Secondly, "proximity" is not
nor addressed by NERC reliability standards
The double ci-rcuit
from the El-khorn
substation to the Ketchum substation across the top of
eliminatedDol-lar Mountain referenced 1n my testimony was
based on transmission planning consistent with NERC
standards TPL-001--4r ds that configuration has a higher
probability of simul-taneous circui-t l-oss than separately
constructed transmission lines. Unl-imited non-
consequential-
these events
load loss is allowed by NERC standards for
0. Mr. Heck1er
they have a lower probability of
of a single transmission 1ine.
al-so states that the substation is
a sj-ngIe point of failure. Does the fact that both
transmission lines originate in the same substation, the
Wood River substation, destroy the reliability
improvements of the second transmission source?
A. No. The re1iability gains come from
elimination of the single radial source north of the Wood
because
occurrence than loss
River substation. The reliability
substation, in this case the Wood
be addressed with other
substation, itself, is
transmission sources of
facilitles. The
of the "source"
River substati-on, woul-d
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energy. Additionally, there are25
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many signifj-cant differences when considering the
reliability and repairability of substations versus that
of transmission and distri-bution 1ines. Substations are
constructed with steel supporting structures, have much
less exposure to line events, and their fai1ure occurs
much less frequently than transmission l-ines.
Substations, like the Wood River substation, have remote
monitoring and control equipment, which al-l-ows for quick
identification of a failure, remote reconfiguration, and
dispatch of personnel- to a known l-ocatj-on. Additionally,
the V0ood River substation is located just north of Hailey
next to Highway 15 and is much more easily accessed than
portions of the existing transmission l-ine.
0. Do the referenced planning standards address
outages within a substation or simul-taneous loss of
lines ?
A. Yes. The planning standards address failures
of components within a substation but not the l-oss of the
entire substation. They al-so address the Loss of two
transmission circuits. In both cases, unlimited
non-consequential- l-oad loss is allowed for these events
because they have a lower probability of occurrence than
a single transmission l-ine outage.
O. Mr. Heckl-er states that the Company is
justifying the redundant l-ine based on an assumption of
ANGELL, REB 1,6
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future load growth. Is this true and how does he come to
this conclusion?
A. No. The purpose of the redundant transmission
Iine is rel-iable service and, as I stated earlier, the
proposed transmission line is not required to address a
forecasted peak demand beyond the capacity of the
existing transmissj-on line. Mr. Heckl-er's argument in
this section of his testimony has misj-nterpreted or
misrepresented the information contained in the Wood
River El-ectrical Pl-an. First, the plan is designed to
identify the electrical facilities requi-red to meet the
ultimate demand of the plannlng area. The process uses
two separate approaches to identify the eventual peak
electrical demand when the availabl-e private l-and is
fuI1y developed consistent with the area's land use
planning. Second,
that the identified
constructed.
the plan presents a 1ike1y time frame
infrastructure improvements are to be
O
using
in the Northern Wood Rj-ver Va11ey
Electrical Supply Report?
A. No. Customers reqularly
energy technofogy and ask whether
. Do you agree with Mr.
inappropriate techniques
Heckler's assertion of
analyzing local- backup
Local- Backup
l_n
the Company is
those technologies. This most recent analysis,
read articles about
pursui-ng
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No. 3 to my direct testj-mony, was prompted by a Wood
River
ANGELL, REB \1A
Idaho Power Company
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Val1ey resident interested 1n an analysis of the local
energy options. A team of Company engineers gathered
data on available energy resources and referenced prior
solar generati-on and property protection analysis. The
report presents the results of a preliminary study to
provide the northern Wood River Va1ley customers served
by the Ketchum and El-khorn substations with backup
electrj-cal suppJ-y from Iocally-sited generatj-on. The
resources considered in the study are a diesel-
recj-procating engine, natural gas combustion turbines, a
photovoltaic plus battery energy storage system,
geothermal generation, and bi-omass generation.
The analysis was performed using industry-standard
energy resource simulation software, HOMER@, which was
developed by the National Renewabl-e Energy Laboratory
(NREL) . The capital, operatj-ons and maj-ntenance (O&M) ,
and fuel cost estimates for the resources identified
above were obtained from Lazard's Level-ized Cost of
Energy Analysis-Version 9.0 (Lazard 2015a). Idaho Power
also compared the Lazard estimates with pre-engineering
budgetary quotes from several vendors. Additionally, the
Idaho National Laboratory (INL), with more than 1,000 MW
of hybrid power, so1ar, and wind energy systems deployed
at Department of Defense and industry/utility sj-tes
around the world,
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ANGELL, REB ].8
Idaho Power Company
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ANGELL, REB 19
Idaho Power Company
provided
analysis
o.
used by comparing
transmission l-ine
this correct?
A. No. The
independent technical
and report.
Mr. Heckler asserts
review and feedback on the
that the wrong baseline is
agalnst the redundantalternatives
of assumptions
definition of load service levels of peak winter,
property protection, summer peak, and critical- loads.
The Wood Rj-ver Va1ley residents' primary concern is
electric supply during winter conditions when a long
duration outage could resul-t in water damaqe following
frozen pipes, named Property Protection by the team.
Consistent wlth the Company's planning approach, dfl
extreme average temperature of -27" F was sel-ected from
historical data to ensure adequate capacity during these
infrequent large demand periods. An analysis of the
residence cooling rate identified that rotating
distribution circuit service, a\k\a rotating outages,
will not maintain adequate heat to avoid frozen pipes for
al-l customers. The December 31, 20L5, 24-hour l-oad
profile of 1,150 megawatt-hours ("MWh") was a recent peak
compared
selection
but not thethe rate of
and usj-ng hypothetical- conditj-ons. Is
LocaI Backup El-ectrj-c Supply Report
and storage options. The
was based on the team's
Iocal- generation
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ANGELL, REB 20
Idaho Power Company
supplying only critical loads, ds suggested, would not
meet the residents' need for electricity to maintain heat
and keep pipes from freezing.
The local supply duratj-on was informed by the
estj-mated ti-me to replace a remote failed structure
during the winter, and the expected time to receive fuel
based on the following components: l-ine patrol to find
the fai1ure, assessment of restoration time, fuel
purchase, and transport in the
Thusr ds stated in the report,
No. 3, the December 31, 2015,
adverse winter weather.
page 11 of 56 of Exhibit
24-hour l-oad profile of
a base cost.1,150 MWh was used merely
0. Mr. Heckler next
Company
proj ect
to determine
asserts that the wrong costs
were used. Do you have a response?
A. As described in the report, the generation and
storaqe technology costs were gathered from several
sources. Mr. Heckler's Tesla PowerWal-l prices of $250
and $45O/k11owatt-hour ("kwh") are not supported based on
Tesla's prici-ng on its website. At the time of the
report, Solar City would j-nstaIl a Tesl-a PowerWal-l- for
$774/fWfr. Tesla has recently reduced the installed cost
to a range of $500 to $585 /kwh,
https : //www. tesIa. com/powerwal-l-
scale PowerPack is sol-d in the
The industrial/utility
same price range. The
recently contacted Tesl-a about pricing for ain Oregon and was told that. the
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ANGELL, REB 2IIdaho Power Company
PowerPack was not currently distributed in Idaho Power's
service territory. However, drl instal-l-ed cost would be
increased by Iand, site preparation, and interconnection.
Mr. Heckler suggests that the Company analyze
recJ-procating engj-nes similar to those evaluated in the
fntegrated Resource Plan. The cost for reci-procating
engj-nes i-s contained in row 1 of Table 1 on page 9 of 56
of Exhibit No. 3. The cost referenced in Mr. Heckl-er's
footnote 34 of $775lkilowatt ('rkwr') was adjusted to
$800/kW based on the area's higher l-and costs,
interconnection in two locations, and a contingency based
appropriate for a preliminary estimate.
Regarding Mr. Heckler's proposal of storing the 2 MW
generators in Pocatello for dispatch to areas of need,
the Company's analysis was preliminary in nature and did
not consider how the diesel- generators were configured.
The estimate of $800/kW may still- be appropriate for 2 Mw
semi-trailered units. However, unlike loca11y installed
units, the logistics of winter transport, placement,
j-nterconnection, and startup under cold l-oad pickup
conditions would be extremely difficult and 1ikely not
meet the Property Protection defined need.
Mr. Heckl-er al-so asserts that combinations of
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t.he least costly local generation option. Referring to
the past several- Integrated Resource Plans, the
Ieast-cost resource additions have been the Boardman to
Hemingway transmission project followed by reciprocatj-ng
engines. Any combj-nation of other DERs wil-l result in a
significantly higher cost without delivering a benefit to
support the increased cost.
O. Mr. Heckler al-so states that technol-ogy has
changed substantialJ-y and be1ieves an advisory committee
should be convened to eva]uate distributed resource
alternatives. Do you agree?
A. No. Advances in the production and the
increased volume of photovoltaic and battery sal-es have
reduced their prj-ces dramatically over the past decade.
However, today their costr ds shown in my testimony, the
referenced report, and Idaho Power's Integrated Resource
Plan, are not yet competitive with conventiona.l-
technology. The cost differences are so large between
conventional- and new technologies for an appreciabl-e
amount of energy production or storage that it would be
highly unl-ike1y that an advisory committee would develop
a different outcome, and I do not agree with this
recommendation.
O. Does this concl-ude your testimony?
A. Yes.
ANGELL, REB 22
Idaho Power Company
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ANGELL, SURR REB 1
Idaho Power Company
A. Please state your name and business address.
A. My name is David Angell. My business address
is 722L West Idaho Street, Boise, Idaho 83702.
O. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("Idaho
Power" or "Company" ) as the Transmission and Distribution
Planning Manager.
O. Are you the same David Angel1 that has
previously fil-ed direct and rebuttal- testimony in this
proceeding?
A. Yes.
O. What is the purpose of your surrebuttal-
testimony in thls proceedi-ng?
A. The purpose of my surrebuttal testimony is to
respond to issues discussed in the rebuttal testimony of
Idaho Sierra CIub's witness Mi-chael- Heckl-er and the City
of Ketchum's witness Mayor Ni-na Jonas. Along with other
issues, I will inform the Idaho Publ-ic Utilities
Commission ( "Commission" ) as to what Idaho Power has done
to explore and analyze reliability alternatives to a
redundant transmission l-ine as suggested by the City of
Ketchum ("City") and
O. Ms. Jonas
others.
states that the City of Ketchum does
not bel-ieve Idaho Power appropriately addressed or
investigated al-ternatives to a new transmission 1ine,I 25
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ANGELL, SURR REB 2
fdaho Power Company
and, in particular,
alternatives. l Did
local generation and microgrid
at these or otherthe Company l-ook
al-ternatives to a new transmissi-on line?
A. Yes. In response
the Ketchum Energy Advisory
Community Advisory Committee
to requests from members of
Commj-ttee ("KEAC" ) and the
( "CAC" ) , fdaho Power
conducted a high-Ieve1 analysis and determined the
estimated costs of alternatives to a new transmission
line. My direct testimony previously filed in this case
summarj-zes the Company's revlew and analysis of
alternatives to a new transmj-ssj-on line, specifically
those suggested by the City of Ketchum. Angell DI, pp.
13-19. Provided as part of Exhibit No. 3 to my direct
testimony is a report which summarizes an examination of
generation al-ternatives to a new transmission line
titled, Northern Wood River Valley - Local Backup
El-ectrical- Supply Report, October 2076, ("20L6 Backup
Report") as wel-l as a cover letter to the CAC summarizing
and forwarding copies of the report to CAC members. The
a1ternatives examined by the Company and summarized in
the report inc1ude: diesel reciprocating engine
generatj-on, natural- gas combustion turbines, photovoltaic
(''PVrr) sol-ar and battery storage systems, geothermal
generation, and bj-omass generation. The concl-usion
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ANGELL, SURR REB 2A
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alternative examined. AII of the alternatives are much
more expensive than the proposed new transmissj-on 1ine.
In fact, the estimated costs of the l-east cost
al-ternative (diesel reciprocating engJ-nes) are more than
two times the estimated cost of new transmission. The
study identifies the estimated costs to provide a 65
megawatt microgrid with backup generation for a 24 hour
period, which ranges from approximately $57 million for a
diesel- engine system to as much as $955 mil-l-ion for PV
solar with a battery storage system. The costs represent
instal-lation only and exclude operati-ng and maintenance
expenses. In comparison, the cost est j-mate for the
Company's recofiImended transmission routing al-ternative is
approximately $30 mill-ion.
O. Did the Idaho Sierra Cl-ub and the City of
Ketchum accept the analysis of al-ternatives conducted by
the Company?
A. No, both parties contend that there is
insufficient data regarding the al-ternatives, state that
the proper cost-benefit has not been conducted, and
request further analysis by third parties.2 Mr. Heckl-er
contends that some smaller subset of the North Va1Iey's
load could be served by the alternative generation,
distri-buted generation, and/or some combination of
rebuilding the existing l-ine and distributed generation
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resources.
2 Jonas REB, pp. 2-5; Heckler REB, passim.
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ANGELL, SURR REB 3A
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O. Do you agree with Mr. Heckl-er that Idaho Power
could serve a smal-ler subset of the North Val1ey l-oad?
A. No. While 1t is possible, as Mr. Heckler
advocates, that some reduced level of service could be
establi-shed, like serving only part of the North Valley's
l-oad or only providing for backup generation to
"essential- servicesr" it shou1d be noted that many of the
essential services, such as the cities' fire, police, and
the medical- center, already have backup generation.
Putting aside what is technically possible, Idaho
Power does not have the option to plan for only partially
serving a community, or partially backing up load in its
service territory. As a regulated utility providing
essentj-al- service to the public and in the public
interest, Idaho Power must plan for and provide service
to all that request and require such service. The
proposal that a microgrid or al-ternative generation
sol-ution would only be establ-ished to serve a portion of
the North Va11ey l-oad is not a viab1e option for Idaho
Power as a regulated utility. At issue in this case is
that the entire North Va11ey area, over 9,000 customers,
are currently served entirely by a single source, dr aged
138 kil-ovolt ("kV") radlal transmissj-on line, and that
regardless of the excel-l-ent past history of reliability,
the Company believes that j-n order to continue providing
reliable el-ectric service, and
ANGELL, SURR REB 4
Idaho Power Company
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ANGELL, SURR REB 5
Idaho Power Company
to reconstruct the aging
to construct a redundant
new 138 kV transmission
existing l-ine, the Company needs
source of energy provided by the
1ine.
O. Mr.
to only l-ook
Va11ey, that:
Have you had any similar dlscussions
configuratj-ons and redundant service
Idaho National Laboratory ("fNL") ?
A. Yes. My department staff
Heckler states in support of his proposal
the Northat backing up partial load for
[B] ased on my discussions with an INL expert,best practices cal-l- for backup focused oncritical l-oads when faced with very 1owprobability outages. As it was explained to
ffie, when the outage probability gets down to
"five nines" . best practice focuses on
backing up critical- loads under thoseconditions rather than al-1 1oad.
about microgrid
with anyone from the
engineers and I
frequently collaborate with INL researchers. Pertaining
to Mr. Heckler's statement quoted above about backing up
critical- loads rather than all- l-oad, this contention is
not exactly
employed by
service are
accurate. First
the Department
different than
of all, the
Defense for
standards
reliabil-ity of
employed by a
of
the standards
public utility,
area has grown
risk associated
and by Idaho
too large to
Power in determinj-ng when an
be exposed to the continued
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ANGELL, SURR REB 6
Idaho Power Company
with being served by a radial- l-ine. Secondf y, the INL
researcher that I have discussed Department of Defense
microgrid applicatj-ons with stated that the install-ations
wil-l- initiaLLy have redundant sources from the electrlc
utility and then they configure the mlcrogrid to backup
only the critical- l-oad. As previously stated, essential-
services such as fire, police, and hospi-tals al-ready have
backup generation.
O. Under the partial backup generation scenarios
advocated by the Idaho Sierra C1ub, the question could be
asked: Who chooses which of the over 9,000 customers
would benefit from such partlaJ- emergency back-up
generation? Is this an issue?
A. Yes, there would be an issue wlth achieving
equity among customers under such a proposal. However,
redundant transmission 1j-ne,with Idaho Power's proposed
the entire
potential
at a cost
equivalent
microgrid
Jonas, in
sufficiently
that is not
substantive argument
North Valley area wou1d be protected from the
catastrophic loss of the single radial fine and
that Idaho Power has shown to be less than an
level of service from l-ocal generation or
alternati-ve options. Both Mr. Heckler and Ms.
a general
look at
sense, sdy that Idaho Power did not
the case.
and consider alternat j-ves. However,
Neither party has produced any
or analysis of its own to rebut or25
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counter what is contained in the record of this case
regarding the comparatJ-ve cost of potential alternative
generation microgrid solutions for providing service to
the North Va11ey compared to the standard utility
practice, and least cost alternative of the Company's
proposed redundant transmj-ssion 1ine. Simply not liking
the outcome, or not agreeing with the Company's proposed
course of action, does not in itself rebut or invalidate
the analysis completed by the Company which concludes
that all of the alternative generation microgrid
sol-utions have higher initial- and ongoing maintenance
costs compared to a transmission l-ine alternative,
provide el-ectric backup for a relatively short period of
time and/or to a small-er subset of customers, and,
perhaps more importantly, still do not elimi-nate the need
for a redundant transmission system.
O. Ms. Jonas refers to the City's formation of an
advisory committee, the KEAC, and its rofe "to advise the
City on energy issues with a particular focus on striving
toward increased use of renewabl-e energy, conservati-on,
and efficiency" with a specific purpose "to reduce the
carbon footprint of the community and become a greener
community. "4 Has the Company specifically
these issues?
worked with
KEAC members on any of
4 Jonas REB, p. 2
ANGELL, SURR REB 1fdaho Power Company
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ANGELL, SURR REB B
Idaho Power Company
A. Yes. Several KEAC members participated in the
Wood River Renewable Energy Working Group with the
Company, which was intended to better understand the
desire for renewable resources and work col-l-aborati-ve1y
with Wood River Va11ey residents to explore the
feasibil-ity of creating one or more new energy products
to help serve the valIey.
Additionally, a KEAC member participated with
representatives from Idaho Power, the City of Ketchum,
Sun Valley Company, and NRG Renew LLC ("NRG") at the
Rocky Mountain Institute el,ab workshop. During the
workshop, the parties reviewed siting PV solar resources
on pubJ-ic lands. f t was determined that the l-ocal-
oppositlon
development
information
to this would be substantial-
would be l-imited to private
informed the approach to the
and that any
lands. This
sofar analysis
report provj-ded as an exhibit to my direct testimony.
NRG was the only other entity that provided any analysis
during meetings fol1owing the el.ab workshop. Attached as
Exhibit No. 8, is NRG's Ketchum/SunValley Microgrid
Scenarios Presented in 2015. The scenarios inc]ude
evaluation of local combined heat and power ( "CHP" ) ,
community PV solar, natural gas, biomass, and battery
resources. The parties di-scussed the viability of each
of the proposed resources. ft was reallzed that the
"hospital" was a 25-bed medical center and thus it was
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too small- for CHP. NRG was also asked to
to the scenarios particularly with regard
provide updates
to a battery
resource.
followed up
and did not
date. Idaho
To the best of my knowledge, NRG never
with an update of its June 2075 presentation
further participate in the el,ab after that
Power reviewed similar resource options in
The 201620LG as set forth in my direct testimony.
that werereview produced cost estimates similar to the
NRG presentation.
a. Has the Company worked with the City of Ketchum
or KEAC on other issues?
A. Yes. The City of Ketchum participated in Idaho
Power's Wastewater Energy Efficiency and Water Supply
Optimization Cohorts. The Company has al-so worked with
the City of Ketchum developing an e1ectric vehicle
charging station and distributed generati-on located at
City Hal-I. fn addition, Idaho Power offered a $300
incentive for RevUp Blaine participants to offset the
cost of purchasing and installing a Level 2 home charging
station for el-ectric vehicles.
O. Ms. Jonas states that a goal of the KEAC is
promoting energy efficj-ency and that "These energy
efficiency goals contrast with the Company's portrayal- of
rising demand in this area. Additionally, Mr. Heckler's
testimony shows problems with the Company's assumptions
and portrayals wj-th respect to population growth, outage
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events, and load demand. "5 Do you have any response to
these statements?
A. Yes. First, ds discussed in prevJ-ous
testimony, the Company's request in this matter is
prlmarily based upon reliabil-ity as opposed to increased
capacity needed to serve growing load. The Company's
obligation to reliably serve customers j-n the North
Va11ey requJ-res a redundant source to mi-tigate the risk
of catastrophic l-oss of the aged radial- 138 kV l-ine that
currently is the sole source serving the entire North
Va11ey. However, load in the North Va1ley j-s continuing
to grow. Idaho Power has added 278 customers 1n the l-ast
10 years.
100 hotel
This includes a single customer with nearly
rooms, and several time-shares and resj-dences.
Another developer has begun constructj-on on a 62-room
hotel- and resident building, which is schedul-ed for
completion in 2019. Idaho Power was required to add an
additional distribution circuit to the Ketchum substation
to accommodate these developments.
Secondly, the promotion of, and potential-
realj-zation of, energy efficiency and/or carbon reduction
efforts in the North VaIley does not necessarily equate
to Iower demand for el-ectric servi-ce from Idaho Power in
the North Va11ey, ds suggested by Ms. Jonas. For
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reduction of the
proliferation of
increased demand
in the area.
area's carbon footprint through the
resul-t inel-ectric vehicles could
new line route to foll-ow an overhead route
for electric service and i-ncreased load
0. Ms. Jonas also refers to the testlmony of Cox
and states thatCommunications ( "Cox" ) in this case
although "The City understands how co-l-ocation may be
support "overbuildingdesirable" that the City does not
of redundant lines or overbui-Iding on a repair of the
existing line any more than absolutely necessary to
accommodate existing services on the poles. Heightening
of poles should be restricted to a minimum to preserve
the character of these communities."6 Do you have any
additional information regarding Cox to provide?
A. Yes. I be1ieve what Ms. Jonas is referring to
is the fact that as part
the
of the second transmission Iine,
the Company proposes first 10 mifes of the proposed
generally
along Highway 75,
distribution line
Cox currently has
existing overhead
Cox has testified
l-ines are kept to
6 Jonas REB, p. 6
replacing an existing overhead
that currently runs along that route.
its facilities l-ocated on Idaho Power's
distribution poles as pole attachments.
that if the proposed new transmission
their minimum heights, dS required by
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the permitting authority, Bfaine County, then it will- no
longer be abl-e to attach its facil-ities in an overhead
configuration and wil] be required to bury its facilities
at a greatly increased cost.
Idaho Power was initiall-y denied its conditional- use
permit application for this line route with Bl-aine
County, and has recently submitted its appeal of the
Blaine County Planning and Zoning Commj-ssion to the
Bl-aine County Board of County Commissioners. As part of
Idaho Power's Blaine County conditional- use permit
application, the Company submltted two different proposed
pole heights: one that contlnued to allow sufficient
room and cl-earance f or Cox' s facil-ities and a shorter
configuration that woul-d represent the shortest height
for the overhead 138 kV poles as requested by the County.
As stated in Idaho Power's Appeal Brief submitted to the
Blaine County Board of County Commissioners, Idaho Power
has continued to work with Cox to develop an attachment
plan that wil-l- al-l-ow Cox to attach its cabl-e to the
shorter transmission line po1es. Accordingly, the tal-l-er
poles submitted as part of the permitting application are
no longer required, only the shorter poles wou1d be
applicable, and could incl-ude the pole attachment.
O. Mr. Heckler is crj-tical- of the Company's CAC
process stating, "the CAC process was run in such a way
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that it effectively only addressed redundant line based
solutions. "7 Is this true?
A. No. The CAC process was not run in such a
any analysis of alternatives tomanner as to preclude
redundant line based solutions. However, the express
purpose of the
with other CACs for the other geographic areas
territory, is specifically to
jurisdictions and interested
decisions that go into the
CAC for the Wood Rj-ver Electrlcal- P1an, as
convened
of the Company's service
make sure that the l-ocal-
parties
planning
are involved with
and siting of transmission lines and associated
infrastructure in their communities. The CAC's purpose
is expressly to provide l-ocal- input into the transmj-ssion
and substation plannj-ng process. However, in this case,
the CAC was specifically given a "no-line choice" as an
option, and al-ternatives to additional lines were
discussed and explored wlth the CAC.
As referenced in my di-rect testimony and cover
l-etter to the members of the CAC, during the 2007 CAC
process, Idaho Power shared information about al-ternative
energy generating technologies. The discussion included
wi-nd, solar, geothermal-, fuel cells, and combustion
turbine technologies. At that time, Idaho Power
identified that smal-l--scal-e sol-ar coul-d provi-de energy to
the region butI25
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intermittent qualitj-es .
suitabl-e geothermal electric generating
Moonstone area but noted that it would
electrical transmission to de]iver the
VaIIey residents.
O. Did Idaho Power undertake any other efforts
would not act as a true
during this time specific to
al-ternative resources in the
A. Yes. As referenced
the 2016 report cover letter
backup source because of its
Idaho Power also identified a
resource in the
still require
energy to North
the exami-nation of
North Va11ey?
in my direct
to the members
testimony and
of the CAC,
since 20L4, Idaho Power has taken part in three primary
activities to explore alternative energy generatj-ng
technologies in relation to the Wood River Va11ey.
Firstr ds noted above, Idaho Power brought together a
Wood River Renewabl-e Energy Working Group to better
understand the desire for renewable resources and work
collaboratively with Wood River Val1ey residents to
explore the feasibil-ity of creatj-ng one or more new
energy products to help serve the valley. The group
explored the f ol-lowj-ng electric generation resources:
sofar, wind, geothermal, hydro, fuel cel-l-s, batteries,
biomass, and biodigesters. The group afso developed
revisions to Idaho Power's Green Power Program to enable
customers who desired to reduce their reliance on
coal-fired generation to offset a portion or
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all of their energy use with renewabl-e energy through the
purchase of renewable energy credits, or green tags.
Second, backup power questions continued to be
raised by local residents, as previously discussed, about
alternative generation microgrid sol-utions to a redundant
Ij-ne, and Idaho Power conducted and provided the analysis
summarized in the 20L6 Backup Report, resulting in
conceptual cost estimates for a storage and diesel
project. This analysis and these estimates revealed that
the cost of such options, particularly storage, far
exceeds the estimates for a redundant transmission l-ine.
Third, in 2015 and as dj-scussed above, Idaho Power
attended and participated, along with representatives
from the City of Ketchum, Sun Va11ey Company, and NRG, in
the Rocky Mountain Institute el,ab Accelerator workshop.
This workshop was focused on col-l-aborative innovation to
address technical barriers to the economic deployment of
distributed resources. Idaho Power provided load data
and ideas at the workshop and developed the two report
appendices to the 20L6 Backup Report following the el,ab
workshop in continued support of the col-laborative
ef f ort. Idaho Power engj-neers spent considerable t j-me
working on the Rocky Mountain Instituters el,ab
Accelerator project.
O. Does Idaho Power have any other process or
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forum whj-ch examines the prudent acquisitj-on of
generation
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resources needed to meet the Company's obligations as a
public utility to reliably serve l-oad in a cost-effective
manner?
A. Yes. The Company's long-term integrated
resource planning process is required to continually
evaluate how the Company can reliably meet the growing
demand for electric energy, and resul-ts in the Company's
Integrated Resource Pl-an ("IRP"). The development of the
IRP is a public process, mandated by both the Idaho and
Oregon public utilities commissions, and filed biennially
for review and acknowledgment with each commission. The
goal of the IRP process is to identify sufficient
resources to reliably serve the growing
within Idaho Power's service territory,
cost, risk,
and ba]anced
and envi-ronmental concerns
demand for energy
while balancing
and giving equal
demand-side, andtreatments to supply-side,
transmission resources. The Company strj-ves to involve
the public in the IRP process in a meaningful way. The
Company recently filed its 201,7 IRP with both the Idaho
and Oregon commissions.
0. Is the Company aware of whether or not Mr.
Heckler participated in the Company's long-range IRP
planning process?
A. Yes. Mr. Heckler attended most of the
Company's public IRP planning sessions. Nevertheless, it25
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appears that many of the j-ssues that Mr. Heckl-er
criticizes as lacking in the CAC process or eval-uation of
alternative generation resources are j-ssues that are more
appropriately reviewed and considered as part of the IRP
process.
O. Mr. Heck1er, in taking exception to Commission
Staff 's witness Michael Morrison's conc]usion that l-ocal
generation and storage options exceed the costs of the
Company's proposed transmission 1ine, admi-ts that "DERs
Idistributed energy resources] may not cost-effectively
substitute for a redundant line" but continues to state
that "the data in the current record is based upon
need forunreasonabl-e assumptions
DERs to back up entirety
consider a combination of
state that "a combi-nation
related to cost, the
existing right-or-way combined with some amount of DERs
could potentially supply reliable electric service j-n the
North Wood Rj-ver Va11ey. " Is it appropriate to make such
decisions, as suggested by Mr. Heckler, in the context of
transmission and substation planning, the CAC, or in the
eval-uation of a Certificate of Public Convenience and
Necessity for a redundant transmission line?
A. No. Decisions about the cost-effective
addition of generation resources is primarily conducted,
of Ioad, and the failure to
resources."S He goes on to
of a rebuilt line on the
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vetted, considered, planned, and ultimately executed as
part of the IRP planning process.
O. Did the Company's IRPs indicate a need for
additional generatj-on?
A. Idaho Powerrs last two IRPs established that
the Company is currently generation surplus or sufficient
to meet the expected demand for energy through the year
2024 (20L5 IRP) and through 2025 in the recently filed
20L7 IRP. The Company currently has surplus generation
available; thus, constructj-ng additional generatj-on in
the Wood River Va1ley woul-d be contrary to the Company's
Commission-acknowledged IRP. Many of Mr. Heckl-er's and
the Idaho Sierra CIub's issues regarding consideration of
additional generati-on resources are more appropriately
addressed and considered as part of the IRP process, and
not a reliability question about whether it is prudent
for a large segment of customers to remain subject to the
potential consequences of continued servj-ce by a single
radial- transmi-ssion line.
a. Mr. Heckl-er discusses a "temporary shoo-f1y
Isic] l-ine" in both his direct and rebuttal testimony.e
Are his eval-uations and statements correct?
No. Mr. Heckler's testimony onto introduce confusi-on as to what
A
appears
thi-s issuea shoe-fly line
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and refers to the shoe-fIy l-ine as
itself to either provide redundant
is and represents in this context. Mr. Heckler portrays
in and ofan ttoptiontt
servi-ce or asa
facility that would stand in the place of redundant
service. Neither is the case. A shoe-fIy line, ds the
Company's refers to a shoe-fIy--or temporary--Iine, is
not an alternative route or service option. Tt is simply
a practical construction technique that woul-d need to be
employed in the reconstruction of the existing l-ine to
avoid extreme and long duration outages of el-ectric
service to the North VaIIey during the reconstruction of
the existing radial line. Further, Mr. Heckl-er
inappropriately assigns some mal-feasance to the Company
regarding a perceived lack of analysis or lack of
assigning importance to the shoe-f1y l-ine "option"
stating, "fdaho Power denies the value and practicality
of the temporary shoo-fIy Isic] line due to its perceived
fau1ts"10 and "Do you see other reasons why the shoo-fJ-y
Isic] option has been undervalued and insufficient]y
analyzed in the current record?"11 The main point of any
reference to a shoe-fly, or temporary, l-ine is with
regard to either (1) wasting the unsalvageabl-e investment
in constructing temporary facil-ities required in order to
rebuj-1d the existing radial- l-i-ne, and subsequently
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removing such
or (2) rather
facilities after construction
than
is completed,
temporary
existing radial-
that i-nvestment
redundant line
complete
no need for a
a
l-ine to facilitate
wasting money building
reconstruction of the
line, and then removing such facilities,
could be better applied toward a second
that if constructed woul-d facil-itate the
reconstruction of the existing line with
shoe-fly. As stated in the Company's Application, p. 3:
Today, beyond the continuing need to servegrowing 1oad, there are two compelling reasonsthat now require the construction of this
second 138 kV transmission line: (1) the
increased rel-iability provided by a redundant
source of energy and (2) the need to
reconstruct the existing and aging 138 kV
radial transmission l-ine without long-term
disruption of service to the North VaIley
O. Is Mr. Heckl-er correct in hls references to
cost and "cost efficient" in relation to what he portrays
as a shoe-fIy option?
A. No. I believe Mr. Heck]er 1s either
misrepresenting or misunderstanding the nature of what a
shoe-fIy line is and, consequently, what relevancy the
cost of said shoe-fIy, Lf required, has. He states, "In
my direct testimony (see chart on page 22), I presented
information regarding the >$25 mil-1ion savings avail-able
f or: (1) a rebuild versus a redundant l-1ne versus (2) a
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rebuil-d plus a shoo-fly [sic] l-ine."12 He al-so states,
"We previously provided testimony that re-building the
existing line (including the cost of the temporary
shoo-fIy Isic] l-ine) is much more cost efficient than
both building the proposed new l-ine and re-building the
existi-ng 1ine." It appears that Mr. Heckl-er's point here
is that it is less expensive to not buil-d a second line
at all-. This is obvious but has nothing to do with the
construction of a shoe-fIy l-ine. Simply reconstructing
the existing radial line, while less expensive than
reconstructing the exj-sting line and constructj-ng a
second, redundant 1j-ne, does nothing to address the risk
associated with the entire North Va11ey continuing to be
served by a singJ-e source, radial l-ine. Again, one
advantage of constructing a redundant transmj-ssion Jine
is that once the second l-ine is completed and in service,
the existing radial line could be taken out of service
and rebuilt without the necessity of utilizLng
construction techniques such as the temporary
construction of a shoe-f1y and wasting the additional
investment to essentially build a second line and then
tear it out after reconstruction.Additlonally, with
the North Valley,
a
redundant transmission Iine
maintenance, repair, outage,
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Ioss events on
serving
or line
any
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either l-ine could be repaired with no
service to the North Va1ley.
O. Mr. Heckler states that both
First, the referenced "future
j-mprovements" refers to the voltage
my direct testimony, which is used
transmj-ssion system that serves the
voltage control-
controf identified in
to support
LincoIn,
disruption of
the
Staff witness, Mr. Morrison, have "failed
Company and
to consider the
value of benefits that installing DERs (e.9. generators
or storage) could provide both in the NWRV [North Wood
River Val-l-eyl and to the larger system. "13 He further
states that these benefits include " (i) the potential- use
of DERs as offsets providing savings against future
voltage control improvements that are projected to be
needed at the Ketchum substatj-on; and (ii) providing
ongoing grid services Ilke peak power shifting and
emergency power.'r14 Can you estimate the DER val-ue
streams of voltage control-, peak power shlfting and
emergency power?
A. Yes. I wil-l- address each of the proposed DER
value streams suggested by Mr. Heckler.
Hai-Iey, Ketchum, EIkhorn, Moonstone, Toponis,
the 138 kV
S i Iver,
and Pocket
substations. Idaho Power's transmission planning studies
indicate that a 12 MVAr capacitor bank, with a total
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estj-mated cost of approximately $350,000, will be
required in about the year 2027 for voltage control-
support. The equivalent l-evel of voltage control
support, if provided as suggested by Mr. Heckler, would
require, dt the l-east, to be offset by 10 MVA of
dispatchable DER at an estimated cost of approximately
$8.7 mi11ion, assuming di-esel reciprocating engines woul-d
be used, which are currently the least-cost DER.
Second, the val-ue of peak power shifting may be
determined from the forward pri-ce curves for the Mid-C
market. The curves rise from approximately $30 to l-ess
than $45 per megawatt-hour 10 years out from today.
These prices are less than the dispatch cost of diesei-
generation and simply do not produce the "val-ue stream"
proposed by Mr. Heckler.
Lastly, the DERs could also be configured for mobile
emergency power, as referenced in Mr. Heckler's rebuttal
and propbsed in his direct testj-monyr ls with infrequent
use during l-ine construction and other natural di-sasters
or emergencies. This is an option sometimes employed by
the Company such as to power small remote towns l-ike
Yel-l-ow Pine, Idaho, and Jordan Va11ey, Oregon,
respectj-veIy. However, a mobile generation configuration
would exceed $10 million and, as stated above, the cost
of fixed l-ocation
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generation is not
expensive mobile
In summary,
solution, current
the proposed
the increased
source of
cost-effective, much less the more
generatlon.
based on the alternative voltage control
energy prices, and
mobil-e generation, the val-ue streams
by Mr. Heckler do not come close to
of DER over the planned addit.ion of
infrequent use of
for DERs suggested
supporting the cost
transmission,
line
capacitor banks, and other l-ower cost utility sol-uti-ons.
O. Do you have any concluding remarks?
A. Yes. As previously stated, the Company has two
compelling reasons that now require the construction of
additional- 138 kV transmission l-ine: (1)
reliability provided by the redundant
continuing
and (2) the
energy by mitigating the risk posed by
to serve the North Valley with a radj-al
need to reconstruct
138 kV radial- transmission line
the existing and aging
without long-term
disruption of service to the North Va1Iey, without
wasting investment on a temporary 1ine. The Company has
demonstrated the need for the redundant l-ine, has worked
col-l-aboratively with the North ValJ-ey community,
eval-uated numerous alternatives to the viab1e solutions,
and has concluded with an economic equj-valent to the
Iowest-cost route option that provides a better level of
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ANGELL, SURR REB 25
Idaho Power Company
Idaho Power respectfully requests that
Commission issue an order: (1) specifically
the
the present and future public
requires the construction of a
convenience and
finding that
necessity
new 138 kV transmission
l-ine and related facilities to provide redundant
transmission service from the Wood River substatlon, near
(2) specificallyHailey, into
granting the
and Necessity
the Ketchum substation and
Company a Certificate
for the construction
of Public Conveni-ence
of such l-ine and
facil-lties identified in the Company's Application as
Such facilities areUnderground
required for
Transmission-TP1.
Idaho Power to meet its obligation to
in the public interest,
that l-ine that must traverse
reliably provide service
includj-ng the portion of
downtown Ketchum with an underground configuration.
O. Does this concl-ude your testimony?
A. Yes.
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CSB REPORTING
(208 ) 890-5198
ANGELL (X)
Idaho Power Company
(The following proceedings were had in
open hearing. )
MR. WALKER: The wi-tness is avail-abl-e for
cross-examinati-on.
COMMISS IONER ANDERSON :Thank you.
. Adams.
Chair.
Let's
begln with Rolling
MR.
Rock Properties, Mr
ADAMS: Thank you,
CROSS-EXAMINATION
BY MR. ADAMS:
o
A
o
Good morning, Mr. Ange11.
Good morning.
On l-ine excuse me,on page 20 of
bottom there,
your
linedirect testimony, Mr. Angell, dt the
21,
had
This
you state, "Historically,
a relatively good service
this particular line has
record for reliability.
was one of the reasons that the previously issued
and necessity wascertj-ficate of public
withdrawn in 1995."
convenr-ence
Do you see that?
A Yes, I do.
O So you agree, and in fact, all parties in
this case seem to agree, that the historic reliabil-ity of
the existlng l-ine was good?
A Yes, that's in the record.25
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O But then you go on in the next l-ine to
state without significant changes to the existing line,
Idaho Power expects to experience more than 209 minutes
of outages per year. Do you see that?
A I do see that.
0 And 209 mj-nutes, is that more than the
l-ine has experienced on average in the past?
A I do not have that information in front of
me. What I could do is I could point you to other points
of the test j-mony describing I believe j-t's in my
rebuttal- testimony -- the rel-iabil-ity numbers of the line
compared to the average for Idaho Power Company, 138 kV
transmi-ssion l-ines.
O Right, I think you go into that on the
following page, page 21; correct?
A Yes.
O The point is you're suggesting here,
aren't your the 209 minutes per year would be an
unacceptable leve1 of outages; right?
A Yeah, this case is all- about reliability
for the North Valley and that assuming the rel-iabil-ity of
the future of the transmission l-ine that exists today
wil-l be the same performance that the past is not
reasonable, and we do anticipate that the outage rates on
the transmission line, both planned and unplanned, wifl-
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CSB REPORTING(208) 890-5198
ANGELL (X)
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
be increased, wil-I increase over time.
O
if the line
instances of
correct?
A
expectation
And so when you say that, what
is not rebuilt, then there wil-l- be
outage up to 209 minutes per year
you mean r_s
increased
or more,'
of transmission
servicer we take
have beyond this
but even if the l-ine is
4,000 miles of we11,
and 100across southern Idaho
into account the information
Yeah,
based on
rebuilt, the
4,000 mil-es
years of
that we
one 12-mil-e transmission l-ine to assess
what we woul-d expect outage rates to
l1ne based on the miles
be for any
transmission that they are built,
so there will continue to be outages is what T'm saying
in the future on thj-s transmission line regardless
whether it' s buil-t or rebuilt.
o
j-s assuming
A
O Okay,
A Yeah,
have the information
minutes actually
line and al-so the
transmission l-ine
looks at kind of
average
in our
rates of
history of the
KV
But your 209 minutes or more figure here
it' s not rebuil-t; correct?
That is correct.
but nobody in this
l-et me rephrase that, and I don't
exactly in front of me, the 209
the past
the 138
exactly what other data
and I can't remember
that, but it did take
system,
went intoI)tr,
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
into account history, average performance, and expected
performance in the future.
O If the l-ine is not rebuilt, correct, in
the context of
A You know, I canrt remember for sure
whether it was rebuil-t or not rebuilt, but anyway, so
what I would state is that I'm going to read what it
states. It states , " . .. that without any significant
changes to the existing North VaJ-1ey transmission line,
the expectation could be that the current configuration
will result in an average duration of sustained outages
of more than 209 minutes per year'ri so when it states
about a current configuration, you might interpret that
to be that a radial transmission line could be have an
outage rate of 209 minutes per year, which is the exact
conditions that werre in today.
O f'm sorry, could you restate that? I
didn't quite fol-Iow your last statement.
A The expectation could be that the current
conflguration, whj-ch is a radial- transmission line, will
result in an average duration of sustaj-ned outage of more
than 209 minutes per year.
O Right, but l-ike you just noted, you state,
"without any significant changes" and so if the line were
rebuilt, wouldn't that be a sj-gnificant change?I 25
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CSB REPORT]NG(208) 890-s198
ANGELL (X)
Idaho Power Company
A That would be a significant change.
Another significant change would be incorporating a
redundant transmission line to serve the North VaIIey.
O But nobody j-n this case is suggestj-ng that
you shouldn't rebui1d the existing l-ine; is that
correct?
A That is true. I think we have a pretty
fair consensus in the case that rebuilding the
transmission line, the existing transmission l-ine, is
necessary.
0 So the questlon is whether we need a new
redundant permanent
whether a temporary
A That
case before us is whether you
public convenience and necessity
line in order to rebuifd that l-ine or
l-ine woul-d suffice?
is the case before
know,
for a
us today. The
a certificate of
redundant
transmission 1ine.
O Okay; so going on to page 23 of your
testimony, lines 2 to 6, you're discussing the temporary
transmission line option and you state
A Just a minute. Okay, now I'm ready.
O Irm sorry, are you there now?
A Yes.
O You state here on l-ines 2 to 6 that a
temporary overhead line into Ketchum would "al-most25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
assuredl-y be deemed a vj-sual- impact by the North Va11ey
customers. " Now, you say "al-most assuredly, " but in
reality, we don't really know if the local- government
authorities up there would approve the temporary l-ine or
not, right, because it wasn't submitted as an option to
the citizens advisory committee or the Bl-aine County
Commission; correct?
A Yes, there has been no request for
building permits or conditional- use permits regarding
temporary transmission l-ines.
a Don't you think those bodies would be
interested in knowing that that's a possible option on
the tabl-e?
A It's not a possible option
It's a construction technique in order to
facility out
either make
for redundancy.
take a radial-
Power's planning
wel1, in your words
of service and maintain service while you
repairs or rebuil-d a radial service.
O Mr. Ange11, I
rebuttal testimony at page 5,
here about your dj-scussion of
want to move on to your
and I have some questj-ons
Idaho
standard that a single
at li-nes 2 to 6 there
at a single substation
megawatts, fdaho Power
on page 5, you say, "Once peak load
is projected to exceed 40
planni-ng standards require a
substation
second transmission source and transformer. " Do you seeI25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
that ?
A I do see that, yes.
O Okay, could you expla j-n whether you're
saying here that the 4O-megawatt limit is the amount of
power that can flow through the Wood River substation on
to a single radial line or the 40-megawatt limit is the
amount of power that should be served off of the Ketchum
substation?
A I'm not saylng any of those thlngs. What
I'm sayinq is Idaho Power has a planning standard that
says when we forecast the load for a particufar
substation to exceed 40 megawatts, w€ initj-ate a process
to add
Iine, a
doesn't
a second transformer and also add a transmissi-on
example.has two
transformers. One is 30 megawatts in size, another one
is 44.8 in size. The Elkhorn substation has two
transformers. It has one that's 10 megawatts, 10 MVA in
size, two of them actualIy, 10 MVA in size, so with your
askj-ng questions about 40-megawatt l-imits, that's not
what this 1s about. Itf s not about l-imits.
O So there is no 4O-megawatt limit, then?
A When 40 megawatts are exceeded, forecast
for a particul-ar substation, we look to install a second
second redundant transmissi-on
mean necessarily -- Sor Iike,
Ketchum substation already
Iine, but it
I'11- give you an
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CSB REPORTTNG
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
transformer, if that's necessary, and we also look to
install- a redundant transmission line.
a
the planning
line, that's
their rul-es;
A
but i-t is consi-stent
Okay, but the requirement to instal-l- or
standard to instal-l- a second transmi-ssion
not a requirement of the Idaho PUC or any of
correct ?
That is correct. It's not a requirement,
with other utility practices and we
bel j-eve it's consistent with NERC reliabil-ity planning
standards.
O But it's not actually the requirement
the NERC, which is the North American El-ectric
Reliabil-ity Corporation?
A Yeah, thank you. It is not the
requirement, because they don't have jurisdiction
well, they have jurisdiction over transmission, but
don't have jurisdiction over a particufar substatj-on
retail- service from a distribution substati-on.
O And other util-ities use different
standards than 40 megawatts,some higher, some lower;
correct?
A That is correctr ds stated in my
testimony.
o Mr. Angel1, I'd like to go back to your
direct testimony on page 29. On this page you're
for
they
and
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CSB REPORT]NG(208) 890-s198
ANGELL (X)
Idaho Power Company
discussing the overhead transmission option that would go
into the Ketchum substation by crossing over through
Elkhorn over Dol-l-ar Mountain. Do you see that?
29 before me.A Yeah, I
a And you
reaI1y meet the needs,
have page
state that
because the
the new redundant
this option doesn't
proximity of the
line, in your words,existing l-ine to
does not provide
A]
truly
donrt
redundant transmission service.
believe I used the term
"proximity" anywhere in this statement.
O Excuse me?
A
o
A
o
A
Do
No,
oh,
I'm
O Okay, weII,
because the two
proximity
two lines
anywhere.
woul-d
I use the word "proxj-mity" somewhere?
that was my paraphrase.
okay.
sorry.
I dld not state
the you
that'sagree that
why --
lines are close nearby,
the industry
North Electric
process works
No, I woul-d not agree
Okay.
Two lines on a common
and so when I mentioned
Reliability Standards,
with essentj-a11y all the
with that all.
tower is known by
the NERC standards,
that standard
electric util-ities
A
o
A
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
across both the United States and Canada and collectively
through a ball-oting process modj-f ies standards over time.
Through that process, all the util-ities have recognized
putting two cj-rcuits on a single tower structure
configuration, such as what would be requi-red to go
across Dollar Mountaj-n, results in a higher probability
of both circuits being outaged, and so then it directs
rel-iab1l-ity planning studies and l-oad l-oss expectations
as written in my testj-mony that are more significant than
two separate transmission lines that are independent.
O Even if they're rlght next to each
other?
A Even if they're
That's based on history. It's
right next to each other.
just the
of mil-es
util-ities have,
you
and
know, hundreds of thousands
the fact that if you put two
expectation is that
of experience
circuits on a single
those will-tower, your
service at
tower built
go out of
independentsome point in time,'
transmission l-ines
whereas, two
aren t t
In fact,
time.
subjected to the
will- not be
I participated insame outage.
at one point l_nthese processes
The Western Electricity Coordinating
Council-, known as WECC, dealt with these parti-cu1ar
standard issues in quite a bit of detail-, and so we had
at one time included some work and criteria to look atI25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
various configurations, and
resulted in is we stick with
at the end of the day what we
utilize thestick, we
NERC planning standards, which again, ds I stated,
acknowl-edged the difference between two lines built on a
single tower configuration versus separate
tower-constructed transmissi-ons .
O So you donrt agree, then, that two l-ines
that are next to each other woul-d have a reduced
reliability in terms of redundancy as opposed to two
Iines that weren't next to each other?
A Wi-th regard to consi-dering the outage of
those two lines, plannj-ng standards requJ-re certaln
performance and they do not require any additional
performance regardless of proximity. fn fact, the
planning standards themselves afso acknowledge the fact
that to get j-n and out of a substation requj-res
transmission lines to be in proximity, and so for the
first mil-e out of a substation, different standards apply
versus the rest of the transmission line. Even crossing
of transmission l-ines does not require any additional
study requirements
O But
performance-wise .
the point 1sn't just to meet the
correct? Itrs to actually preventplanning
the power
standards,'
from going out?
A Well, certal-n1y. I mean, yes, the desireI25
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CSB REPORTTNG(208) 890-s198
ANGELL (X)
Idaho Power Company
is to provide reliable service, but, again, you have to
take into account performance history as to, you know,
transmission lines being in common corridors. As you can
expect, most transmission l-ines aren't placed in common
corridors and that 1s just
at that
a fact of siting transmission
1ines,
Iines
and looking and the performance of those
in the corridors, the data shows that the
performance is satisfactory.
MR. ADAMS: Mr. Chairman, may I approach
the witness with an exhibit?
COMMISSIONER ANDERSON: You may.
(Mr. Richardson distrlbuting documents. )
MR. ADAMS: So this exhibit is Idaho
Power's response to Rock Rolling Properties' production
request No. 3 and -- well-, If l-l move to admit the exhibit
first, Chair. It would be 801.
COMMISSIONER RAPER: You already have 801.
MR. ADAMS: 802, excuse me, Irm sorry,
802.
(Rock Rolling PropertJ-es Exhibit No. 802
was admitted into evidence. )
COMMISSIONER ANDERSON: Without objection,
1t is admitted.
MR. ADAMS: Is the exhibit admitted,
Chair?t 25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
obj ection.
was waiting.
O BY MR. ADAMS:
production request asks Idaho
redundant line woul-d prevent
that because the outage on the
l-ine on August lzt-h, 2014, was
weather event could have also
l-ine?
COMMISSIONER ANDERSON: Without
COMMISSIONER RAPER: It was.
MR. ADAMS: Excuse me?
COMMISSIONER ANDERSON: Yes.
MR. ADAMS: Oh, okay. Excuse me, sorry, I
Ange11, this
to identify how the
that had occurred onoutages
the existing l-ine over the past 10
understood you to just state that
reduced reliability probl-em if the
proximity to each other, but isn't
here, the second to l-ast sentence
So Mr.
Power
years, and so as I
there would be no real-
two lines are in
it true that down
of the response says
138 KVWood River-Ketchum
weather related, that same
impacted the redundant
say that
fact, the
A That is what it states. f woul-d have to
it could also not have impacted that l-ine and in
likel-ihood of it not impacting that l-ine j-s
the fine.much higher than it impacting
O But as it states here,prepared by Perry
alsoi correct?Van Patten, it certainly could have,25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
A That's what he states.
actually might disagree.
O So you disagree with Mr
response?
Yes.
On behalf of
Frankly, I
Van Patten's
Yes,
Okay;
rebuttal testimony, you
assertion that the two
woul-d be in proximity to each
other. Do you see that?
I might
the Company?
just do that.
so I want to on page 14 of your
are responding to Mr. Heckler's
lines that you propose to exist
other and wou]d cross each
A
O
A
O
A
o
your proposal
A
that, Mr.
reference
a l-ittl-e
Let me pu11 the map out,
COMMISSIONER ANDERSON :
I have page 74 in front of me.
Okay, and so there's act.ually a map of
in Exhibit 4; correct?
Adams, if you could identify
please.
While you're
the line when
identify the lines for me just so
doing
you
it'sa page,
easier.
MR.ADAMS:
would be at the bottom. He
Certainly. Yeah, here it
actually quotes Mr. Heck1er's
there, and then on line 30 hetestimony
goes on to
line would
in a block quote
thestate that
not cross and
existing
are not in
line and proposed
proximity to eachI25
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CSB REPORT]NG
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
other
O BY MR.
Exhibit 4 attached to
of the Company's
A Could I
Commissioner? I'm not
COMMISSIONER ANDERSON: Thank you.
ADAMS: So then if we turn to
your direct testimony, that's a map
obj ect
sure I
to what you just
can, but, again,
tol-d the
the term proximj-ty
term with regard --
common towers.
O BY MR. ADAMS:
next sentence, "proxj-mity is
addressed. "
you used
in my writing and I don't use that
they do not cross nor do they share
And then you say in the
not prohibited nor
A That's correct, and, again, I have that in
quotes. That's Mr. Hecklerrs terminology.
O Because you don't like that word?
A I don't choose to use that word.
MR. WALKER: Objection, argumentative.
O BY MR. ADAMS: Okay; so if we look at this
frdp, though, Mr. Ange11, you state the two l-ines don't
cross, so on this map in Exhibit 4 --
A Exhibit 4.
O Are you on Exhibit 4?
A I am on Exhibit 4.
O Okay; so is it true the red line is thea25
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(208 ) 890-s198
ANGELL (X)
Idaho Power Company
existing transmissj-on line?
That is correct.
And the bl-ue and white dotted fine is the
proposed overhead transmission line?
A That is the proposed construction
line and in fact, what wil-l- occur if you were to
of new
zoom r-n
A
o
to that point where they
transmission line and old
appear to cross, the new
transmission line will
of each that are
actually
connectedeach there will be segments
to each other such that they do
O So you're saying
accurately represent that they
not cross each other.
that the map doesn't
cros s ?
A Well-, it can't -- because of the detail,
it can't get into the detail to show how they wil-l-
connect. What it j-s showing is where the construction
and so if you were toOCCUTS,
starting from the Wood River
if you l-ook
substation there
at the map
at the very
inch where
that red
bottom and you go up, oh, maybe about
i-nto the bl-ue dotted
a hal-f
the red line runs
l-ine will -- we're going to
connects to the blue dotted
continue up north to Ketchum.
to the east, so coming
will- be double circuit
Now, al-so, the new construction goes off
from the Wood River substation, it
1ine,
configure it so that it
l-ine and then head --
with the transmi-ssion l-ine thatI25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
comes up from Midpoint, and then that blue line then
again turns back north, and then where it intersects with
the red line again, it will be connected to the red l-ine
and contj-nue up to the Elkhorn substation, so
I specified that in thethey do not
myself.
o Okay; so it's your
bl-ue and white line
testimony that the red
will not actually cross
somehow?
A We wil-l- configure the construction so the
Iines do not cross and that is my testimony.
O Okay; so what is the closest what wil-l-
be the closest distance between the existing and the
proposed l-ine?
A I think about 80 to 100 feet, but f canrt
recol-l-ect.
O So on this fldp, are you generally familiar
with the geography up there in that area?
A Actually, I lived there from 7917 through
the mid '80s.
O Okay; so would you agree that the word
"Bl-aine" on the map is roughly about where Ohio Gulch
is?
A I woul-d say the l-etters "Bl-aine" j-s where
Ohio Gul-ch is.
cross and
in fact,
de s ign
Iine and the
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CSB REPORTING
(2oB ) B9o-s198
ANGELL (X)
Idaho Power Company
O Okay; so from that
furthest distance between the two
point south, whatrs the
1 ines ?
A I do not have a measurement before me
where I coul-d tell you
O Roughly,
A Looking
even read the scale of
o
can I approach
already in the
I
copy of Sierra
response to
state you're
do you have
A
o
Company what
be, correct,
the request
A
Company's estimate
existing line. "
that.
what wou1d you estimate j-t at?
at the scal-e of the map I canrt
the map, sir.
Well, let's move on. Mr. Ange1l Chair,
the witness with another exhibit that's
record, but just so he has a copy?
COMMISSIONER ANDERSON: You may.
(Mr. Richardson approached the witness.)
BY MR. ADAMS: So I'm going to hand you a
Club Exhibit 314, which is actually a
a Sierra Cl-ub discovery request that you
the sponsor of the response. Do you see
that in front of you, sir?
I do have that in front of me.
Okay; so this document
the cost to rebuild the
the discovery request?
was; correct?
Yes, it says, "Please
actually asks the
existing l-ine wou1d
That's roughly what
provide the
for the costs of reconstructing theI25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
o
some analysis
correct?
A
me see here.
o
existing
without
line
Option 1
based on
is the base
there being
for the
Okay, and you provided a document with
that the Company had done that's attached;
Yes, there is an exhibit to wel-l-, 1et
option to rebuild the
a redundant line
redundant line;including any costs
correct?
A I was just reacquainting myself, so if you
would proceed.
O And then Option 2 is what you cal-l- the
shoe-f1y option of a temporary l-ine and that's basically
the same proposal, right, except with the temporary
line?
A Yes, that's what these reflect.
O Okay, and the dlfference between the two
is roughly $3 million based on this document; correct?
A Yeah, that reflects the when
constructing the shoe-f1y and returning the material-s
that woul-d be returned and not expended during the
construction, yeah, the difference is 3.2 mil-l-ion.
O Okay, and so my question is related to the
last l-ine of your narratj-ve response to the production
request here where it states, "lf incremental costs are25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
i-ncurred re1ated to non-standard construction (e.g
building a temporary
reconstruction due to
redundant service), the
assigning these costs to
l-ine to accommodate l-ine
local- opposition to permanent
Company may
the local-
consider directly
j urisdictions
these costs. "Do you
I do see that.
So are
responsible for
see that?
A
o
the incurrence of
Company woul-d propose
$3 mil-lion line to the
you actually suggesting that the
to directly assign the costs of the
l-ocal residents even though the
alternative is the $30 mil-l-ion redundant line?
A What it states is that if incremental-
costs are incurred related to non-standard construction
techniques, the Company may consider directly assigning
these costs to local juri-sdictions responsi-b1e for the
incurrence of those costs, yes.
O Do you agree, though, that if the
Commissi-on determines that that's 1n fact the l-east cost
solution to the problem presented before it that it
wouldn't be fair to assign those costs to the l-ocal
j urisdictions ?
A Yeah, we'll have to await the outcome of
the Commission's ruling.
MR. ADAMS: Okay, thank you, Mr. AngeII.t 25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
Mr
further questions, Chair Anderson.
COMMISSIONER ANDERSON: Thank you.
Richardson.
MR. RICHARDSON: Thank you, Mr. Chairman.
CROSS-EXAMINATTON
BY MR. R]CHARDSON:
Good morning, Mr. Angell.
Good morning.
So there's a reason I dldn't go to
but I am
Adams'
and it was a good
by your response
No
engineering school,
thoroughly confused
questions on
indulgence,
A
o
please?
A
o
A
o
you stated that even
graphically depicts
in fact cross?
O
A
O
one,
to Mr.
your Exhibit No. 4, and with the Chair's
can we go back to that exhibit?
Sure.
Would you reference that exhibit for me,
Reference the exhibit?
Do you
Yeah,
Thank
have that in front of me?
f have it in front of me
you. Did f hear you correctly
though the map, the Exhibit 4,
the l-ines crossing that they do
that
nott25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
O The
depicts the lines
testimony that they c1o not
A The graphic
from the height indicates
A When we construct the l-ines
question is the exhibit graphically
crossing and am I correct in your
appears that they cross, but if one was
closely in to that point, you woul-d see
wire connections that go from -- we1l,
intersect with the existing line, such
other? )
A No, !n.V don't.
O Why.. is this depiction so
A V{e11, I wouldn't say the
wrong. It has to do with the scale.
cros s ?
because of the detail provided
I mean, it looks it
to zoom very
that there'll- be
that
that
actually
in reality
cross eachonce constructed, the two lines wil-l- never
other.
O Do they physically connect to each
wrong?
depictlon is
O And you chose not to give us a
to actually show how the lines relate to each
on the southern part of the project?
scale map
other there
A We do have that scal-e ildp, but we did not
include it in our testJ-mony. It's not part of the
record.
O So you cou1d -- given what we have in25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
front of us,
lines cross,
A
o
you could
couldn't
Sure, I
So how
forgive us for assuming that the
you?
could forgive you.
cl-ose do the lines get to each
other down there?
A Again, I donrt have the details before me,
but
O Is it mil-es or feet or yards?
A It would be feet, sure. Itrs not going to
be mil-es.
O A matter of feet, like two feet? Three
feet? 100 feet?
A No, sir, that would not be reasonabfe.
O Pardon me?
A No, sj-r, that woul-d not be reasonable.
O What wou]d not be reasonable?
A Two or three feet.
O So how many feet are we talklng about?
What is reasonable?
A
O
Like 100 feet, yes.
So the l-ines come within 100 feet of each
other?
A
O
A
That is correct.
That's the closest proximity?
Yes, that wou1d be closest proximity othert25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
than right at the substation as they exit, they'11 also
be approxi-mately 100 feet or so from each other.
O So when they exit the substatj-on, they're
how many feet apart?
A Sir, I do not have the detail-s in front of
il€, but I would say they would be in the range of a
hundred or hundreds of feet as they exit a substation.
O So they're never cl-oser than about 100
feet ?
That is correct.
But they are within about 100 feet?
Yeah.
Literally, how long do they proceed along
that?
A
o
A
o
A
o
A
At 100 feet?
Uh-huh.
Oh, very short dj-stance, so in the range
50 feet.
O And then they diverge
of maybe 20 to
A Wel-l-, ds you can see
diverge to probably in the range of
O f'm not sure where I
to how far apart?
on the map, they
about a mile.
see that on the map.
on the map
and go
Ohio Gul-ch
A WelI, if you were to go look
so you see the Blaine, correct,
canyon above thatis, the next
that's where
where you canI25
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CSB REPORTING(208) 890-5198
ANGELL (X)
Idaho Power Company
see the route
Canyon off to
you're going
other.
o
you couldn't
idea of how
A
of the existing line heads up East Fork
the northeast, out in that point, yeah,
to be more than a mi-le distance from each
We1I, I thought you told Mr. Adams that
interpret the scale of the map and had no
far apart they were.
So I can make some reasonable assessments,
but 1f you want me to get down to detail-s
the l-ines do come cl-ose together, I can't
many feet those are, but I can definitely
where you know, if you were to take a
hand and you know the dlstance between the
a littl-e more than 10 miles between Hailey
think you could scal-e that out and I cou1d
can't get down to the details be1ow a mile
That would be too difficult.
scale
closer where
te1l you how
tel-l-you
of your
is roughly
Ketchum, I
well. I
certain.
two
and
AS
for
aso
the word "B1aine"
cartographer, but
a mile.
the proximlty of the lines up to
mdP,you
1i ke
know, Irm not a
given
on the
that looks less than a quarter of
A If you'Il give me some time, I'11- work on
it, so which portion would you like me to discuss?
O I asked you about the portion south of the
word "Blaine" on your Exhibit No. 4.t 25
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CSB REPORTING(208) 890-5198
ANGELL (X)
Idaho Power Company
A I woul-d say from the word "Blaj-ne" it
ranges from a half
three-quarters of
discussed, they'11
each other.
OSo
single event, that
wildfire, local-ized
cause both of these
a mile and,again, out to
then as wetvea mil-e, and
go to within, sdy, about
in your opinion, is it possible that a
a single event, such as an avalanche,
wind could
time and
ice events, or microburst
fines to fail at the same
about
j ust
100 feet of
still feave the north end with no source of electrical
power?
one at a time, so
l-et me address each one of those
referencing my testJ-mony, can
of those particular line
ASo yeah,
you're
you cite
events?
the page of each
o
I was asking
A
o
I wasn't referencing
opinion
right.
as to whether or not
your testimony.
a single event,
a l-ocalized ice
No,
your
A11
such as an avalanche, a wildfire,
or a microburst wind could disable both of those
event,
lines
besuch that the north end of the valley would
without electrj-ca1 power, and Irm speaking
on your Exhibit 4 from approximately Blaine
Wood River substation.
still
specifically
south to theI25
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CSB REPORTING(208) 890-sl-98
ANGELL (X)
Idaho Power Company
A Yeah, let's take those one at a time
Avalanche woul-d not take both lines out.
O Would an avalanche take one line out?
A Yes, it coul-d.
O But not both?
A But not both.
O Have you done a study of that?
A I don't need to do a study of that. If
you look at the map
O You're an avalanche expert?
A Pardon me?
A You're an aval-anche expert?
A No, Irm not an aval-anche expert.
a So why don't you need to do a study of
that to make that concl-usion?
COMMISSIONER ANDERSON: Mr. Richardson,
l-et's all-ow him to answer the question.
THE WITNESS: Yeah; so if you were to l-ook
at the map itself so I grew up in Hailey and I've seen
a few avalanches and I've seen my friends on their
snowmobil-es caught up in aval-anches, seeing them the next
day at school and seen them pretty shooken up, so I have
some experience being around avafanches and I'm very
concerned about such things personally when I go out
hiking and skij-ng in the winter, snowshoeing, so if yout25
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
were to look j ust
that
south of Blaine, there's a mountain
ridge there
is right up
you can see on this map and the red l-ine
against that mountain, so you can see in that
aval-anche riskshadow of that mountain there's some
there.
As you go north of Blaine and you go up
along that East Fork, you can see the route of the
transmission line is right up against the north side
mountains there and then there's some risk of avalanche
there, but, you know, it's not super bad, and then going
forth from there, so there's kind of just two sections
for significant aval-anche risk. Now, the existlng so
thatrs the existj-ng Iine.
The new transmission l-ine fo]lows the
highway and if you go, again, north of that East Eork
Road, over there on the west side, you can see some
the mountains there and you can see these, where you can
see trees and i-n between trees, you see some brown space
or lighter-colored space, that's an indication of
avalanche chutes, and along those areas, yeah, we've seen
avalanches up there pretty regularly, and so that
transmission l-ine coul-d experience an avalanche issue in
that particular area; however, it is out quite a ways up
against the road because of the sheep trail and so not
super avalanche rlsk, but that wou--d be the area I'd be,q
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
concerned about for that transmissi-on line. Two
completely different avalanche areasr so a single
avalanche wouldn't take both those transmission lines out
of service.
Okay; so next
the transmission
event, a mi-croburst, kind of
looking at l-ine routes, microbursts
probably, again, they can occur in canyons, but I think
where we experience more of our issues for microbursts
can actually occur on mountain tops and so the existing
transmission line does go across the top of Dol-Iar
Mountain. There's some exposure as well as you come east
and south of El-khorn to wind, and so I would say that the
existing line has got some exposure to wind microbursts.
The new transmj-ssion line fol-Iowing the
highway right up the valley, you know, the va11ey, just
my experience, hasn't had microbursts that come right
down through the valley. Let's see, icing, so the icing
events, the issue with icing events is that so you get
fog conditions, hiqh humidity, and that humidity tends to
cling to the conductors. Where the conductors are warm
for carrying the energy up to Ketchum and Elkhorn, those
conductors melt a bit of the ice.
We have shiel-d wires to
Iightning, so
to the ground
what they are
such that if a
are wl_res
lightning
protect from
that are connected
str j-ke occurs, itI25
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CSB REPORTTNG
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
will hit that wire. It basical-l-y brings ground up above
the conductors and so lightning will strike that. They
don't carry any energy and so under the ici-ng conditions,
they build up big and thick ice and they sag down because
of the weight and that was actualJ-y a condition that
resulted in that 2009 outage on the Midpoint to Wood
River transmission line and which has been mitigated. We
moved t.hose shiel-d wires so that they wouf dn't cause that
condition, so the existing l-ine from iclng could be
problematic.
The new transmission li-ne is our low
and does not include any shield wires and
icing wil-l- not be a
for that transmission
are spaced such that
or should not be a problem
again, icing affectlng both l-ines, not 1ike1y.
O BY MR. RICHARDSON: And that's because the
lines have different construction
A Construction techniques, that is
profiJ-e design
the conductors
problem
liner so
correct.
o
don't plan to
technique?
So when you rebuild the exlsting line, you
use the most modern construction
A Oh, well-, that's a good question, so the
new transmissj-on fine and, agaln, construction
technique, it's not really modern or not modern. Thet25
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CSB REPORT]NG(208) B9o-s198
ANGELL (X)
Idaho Power Company
design of the new transmj-ssion lj-ne is to accommodate
both the distribution and the short pole heights, and so
it's a single tower construction with accommodating both
dlstribution and the towers. It's a more expensive
construction, because we have to place towers, sdyr like
every 300 feet or something of that nature. The existing
line is spaced out with towers in the range of about
11000 feet and it's a two-pole structure and going
through rural- areas, long distances, it's a much more
economical- construction technique.
O So you testified earlier that two circuj-ts
on a single
A
a
not provide
A
Jackson Hol-e
Yeah, you know, you
incident from earl-i-er
tower increases the outage probability.
That is correct.
And that two circuits on a single tower do
truly redundant service; correct?
February which is referenced in
with regard to that.
O Woul-d you aqree
single substation l-j-kewise does
redundant service?
coul-d fook to the
this year back in
Vern Porter's testimony
that two circuits on a
not provide true
No, f would disagree with that.A
n
A
On
So if you'11 all-ow me to explain why II25
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CSB REPORT]NG(208) 890-s198
ANGELL (X)
Idaho Power Company
disagree with that, so when we build transmissj-on
systems, so,
build -- so
transmission
for example, across southern Idahor we
across southern Idaho
circuits that operate
build substations along the way.
build what are known as transmission switching stations,
which is exactly what the Wood River substation is, and
the point of the Wood River substation being a
transmissj-on switching station similar to the Midpoint
substation is actually to provide greater reliability, so
let me just kind of wal-k you through thatr so for
j-nstance, dt the time when we built the King line, w€
built it from the Hagerman Val1ey area through Hailey al1
the way up to Ketchum, and we coul-d have just energi-zed
from the Hagerman Va11ey area al-l- the way up to Ketchum
and just had that operate as a radial transmission Iine,
and when we buil-t the l-ine from Midpoint to Hailey, we
started in Jerome and we buj-It only from Jerome right up
to Hailey, and we could have just served Hailey off of
that transmission line, so what that would have resu]ted
in is Hailey wou1d have a radial- service and Ketchum
would have a radial- service, Ketchum-Elkhorn, and so
that's not as reIiable a service level as building the
Wood River substation there in Hailey and connecting
Midpoint to Wood River and Hagerman to Wood River, the
we have 230 and 345 kV
in para1IeI and we
Occasionally we'11
I 25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
King l-ine and
reliability to
werve only got
Ketchum, so in
o
substation?
A
a single point
l-ine.
o
that the
question
confused
then building
HaiIey and that
so that provides greater
area and then, of course,
the radial transmission line going up to
fact substatj-ons improve reliability.
But the fact remains itrs a single
It's a substation, but a substat j-on is not
of fai-lure similar to a transmission
So you would agree with Mr. Youngblood
I'11 strike that. Mr. Adams asked you a
on your rebuttal testimony on line 5 and I
a Ilttle bit by your answer.
A Rebuttal- what page?
line 2
was
Page 5
Okay.
There you talk about once peak l-oad at a
single substation is projected to exceed 40 MW, Idaho
Power planning standards require a second transmission
source and transformer. Do you see that?
A I do.
O And we probably don't need the court
reporter to read it back, but I recal-l you saying that
you l-ook to instal-l-ing a second transformer or
transmission source. You didn't say that you were
o
A
O
f
I 25
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CSB REPORT]NG(208) 890-s198
ANGELL (X)
Idaho Power Company
required. I was wondering if you could cl-ear that up for
us.
A Yeah, so again, it's a projection of that
load out in the future and we're projecting five years in
advance, and at that point i-n time we initiate our
process for siting a transmj-ssion l-i-ne and a transformer.
As you can imagine, installing the transformer in the
substation, because we planned that a second transformer
will be buiIt, that usually goes along pretty smoothly;
however, constructing the second transmissj-on 1ine,
because 1t will- require siting, usually takes more time,
so oftentimes, that transmission line will come later 1n
time, and the l-oad at that substation will probably be
greater than 40 megawatts before we actually get that
second transmissj-on line installed, and we have severaf
examples of that, including the examples in our
testimony.
O But your prefiJ-ed testimony says a second
transmission line is required.
A That is correct.
O And so
A Our planning standards require it. That
establishes that we make
doesn't necessari-1y say
will be there before the
a plan to install it. That
that we will you
hits,
know, that it
40 megawatts but we wil-l-25
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ANGELL (X)
Idaho Power Company
definitely take the actions required by the Company to
provide reliabl-e service by initiating that process to
site a transmissi-on 1ine.
O So I guess that raj-ses the question, who
enforces the requirement?
A As the planning manager, Irm the one
nipping at the heels trying to get these things done.
O But they don't necessarily always get
done?
A They don't get done timely oftentimes
because of the delays in siting, and as you can imagine,
Idaho Power initiated the Boardman to Hemingway
transmission l-ine project back in 2007. From a planning
perspective,
2012. We're the siting process,
we do is we come up
and when things
with other
our desire was to have it in service in
still in
don't come a1ong, what
plans j-n order to
was discussed also
tie switches, tie
circui-ts.
OSo
requirement?
particular case here today. The
substatj-on exceeded 40 megawatts
ensure reliability, and one of those
further in my testimony with regard to
switches to other distribution
you're not always able to satisfy the
A Well, yeah, and the example is this
Ketchum-E1 khorn,
years ago and we stillI25
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don't have a redundant transmission line up there.
O So on page 7 of your direct testimony, you
discuss the compositj-on of the community advisory
committee or CAC; correct?
A Wel-l-, I'm just getting that open here.
Page 1?
O Page 1.
A Yes.
O And beginning on l-ine 9, you talk about
the membership of the CAC as including regional
transportation and growth pJ-anners, various city and
county officials, representatives from the Bureau of Land
Management, United States Forest Service, special
interest groups, business 1eaders, and residents. Do you
see that?
A Yes, I do.
A And wasnft it Idaho Power who determined
who woul-d serve or which category of representatives
would serve on the community advisory committee?
A Category of representatives, meaning the
categories that were just listed?
O I'l-1 ask it more directly. Didn't Idaho
Power determine who was on the CAC?
A fdaho Power, yes, invj-ted members that
fit that met these criteria to join the community
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advi-sory committee.
O And fdaho Power set the criteria;
correct?
A Yeah, Idaho Power set this criteria in
response to our case before the Commission with regard to
the City of Eagle and the Commission requesting that we
engage the local jurisdictions in planning electrical
facil-ities well j-n advance of when they'1I be needed.
O And Idaho Power sel-ected the individual
representatives ?
A Yes.
O So when you note over on page 9 of your
direct testimony on l-ine 11 that a majori-ty of the CAC
supported the Company's proposed line from the Wood River
substatj-on to Ketchum, you're talking about a majority of
individuals Idaho Power sel-ected to make that judgment
call-; correct?
A I would say it wou1d be a majority of
individuals responsible for planning in the l-ocal- area as
described by what you just read off, you know, the
category of individuals present.
A But we have establ-ished, have we not, that
Idaho Power selected the individuals?
A WeII, actually, so ldaho Power when we
went out, we approached each jurisdiction and asked them
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Idaho Power Company
to join and typically, we would get their planning
dj-rector or planning manager or some planning person,
plus an individual- that would have been in a voted-on
position, such as a commissioner or a mayor or a counci1
member, so we had representation both from the governing
body for that jurisdicti-on, plus a hands-on planner.
O So the question was
A Those individuals, I mean, we didn't go to
the county and ask for a certaj-n individual from the
county. We went to the county and the county selected
which indivldual- to join us. Now, outside of those
particular individuals, so like with the city, f mean,
Sun Val-Iey Company, you know, a large industrial- consumer
up there similar to other areas, we go ask them to
provj-de a particular -- we don't ask for a particular
individual. We ask for representation from them, so I
guess
you're
Ird just characterlze it differently than the way
characterizing it.
O I thought you said that Idaho Power
selected the individuals on the CAC. If I'm incorrect
A Yeah, I stated that j-ncorrectly. We set
up the categories and we went and extended an invitation
to the entitles that fit those categories and they
suppJ-ied the individuals. We did not approve or deny
certain individuals that those entities would supply.o 25
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O So the categories included residents;
correct?
A rr did.
O So did you just say, "Residents comer'?
A Oh, Do, actualIy, so what werre also
Iooking for, I mean, you have to have understandlng an
operatj-ng committee, if you get a committee too large,
you can't get anything done, so we like to have some
resident particlpation, and so there were a couple of
members that were residents that participated.
MR. RICHARDSON: Mr. Chairmanr mdy I
approach the wj-tness?
COMMISSIONER ANDERSON: You may.
MR. RICHARDSON: Thank you.
(Mr. Adams distributing documents. )
MR. RICHARDSON: Mr. Chairman, I'm handi-ng
out what's been marked as Exhibit 902. It has already
been admitted as an exhibit in this proceeding at the
public witness evening in Ketchum.
O BY MR. RICHARDSON: Mr. Ange11, do you
have a copy of Exhibit mo. 902 in front of you?
A I do.
0 So referencing Exhibit 902, couldnrt we
concl-ude that it is true that one of the desired outcomes
of the community advisory committee or one of the goals
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ANGELL (X)
Idaho Power Company
was to actually obtain support for the Company's desired
option?
A Yes, one
have community support
advisory process.
O So that
of the desired outcomes is to
for the outcomes of the community
wasn't my question. The question
was one of the goals of the advisory committee process is
to support the Company's desired option; correct?
A And those desired options are developed
wlth the community advisory committee.
O So it's your testimony that ldaho Power's
desires are synonymous with the community's desires?
A In the case of so Idaho Power desires
to build -- excuse me, to provide reliabl-e service to al-l-
customers, and in order to do thatr we have a planning
process to that incorporates community advisory
processes in order to help identify and site facilities
such as transmission lines and substations, and the
reason we do this with those local planning entities is
they have you know, they have their comprehensive
plans and they have land zonj-ng and they know where they
woul-d antj-ci-pate industrial- facilitles to be instal-1ed
and oftentimes, J-ndustrial locations are good locatj-ons
f or substations and transmi-ssi-on Iines.
They al-so know where they woul-d be lookingI25
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CSB REPORTING(2oB) B9o-s198
ANGELL (X)
Idaho Power Company
to encourage development in the future and where
development wouldn't occur in the future, so yeah, we
have these processes, so I'11 just give you the context
of this particular meeting, if you wiII, so foll-owing the
Eag1e, City of Eagle, case which was mentioned earlier,
so Idaho Power began community advisory processes. We
started in the Treasure Valley with our very first
process, and from that process, there were two questi-ons
that came out right off the bat from those members that
were going to participate in those
desired
expect,
process
and you
outcome of thls commj-ttee,
and are you willing to let
change the plans, so those
know what, we've had, what,
processes: Idhat' s the
rightr ds you could
the communj-ty advisory
are the two questions,
seven of these and
every time these same questions come up, so the point of
this particular meeting, which was the second meeting
second advisory process that we had, so new in the
development, we had, of course, a host of new
indivi-duals.
The only person that was involved in the
Treasure Va11ey community advisory process was Kent
McCarthy and he led this meeting, and so the purpose of
this particular meeting as recorded in the minutes is to
bring those members who are unfamiliar with the communj-ty
advisory process up to speed in the process and how itI25
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(208 ) 890-s198
ANGELL (X)
Idaho Power Company
works and so yeah, these particular questi-ons are ones
that those particular individual-s need to understand and
be able to work wel-l- with the communj-ty advisory process,
and so, yeah, you know, this questl-on how wil-l-ing are we
to l-et the committee change our pIans, well, frankly,
going into the Wood River Valley process in fact, I
was the one that directed this process to be initiated,
and where I was focused was on the transmission l1nes
comj-ng
around
into the Wood River substatlon because of concerns
the ability to meet the load l-evel-s that are
into the future for whatrs known as the Woodproj ected
River 1oop, which begins at the Midpoint substation and
goes up to that Wood River substation and back down to
the King substation
great
you'd
O Mr. Angell, I don't mind you explaining in
detail some of the additional information that
Commission to know
Okay.
-- but I was wondering
answer my questions.
to expand --
Okay, sure.
l-ike the
A
o
try to directly
of opportunity
A
O on redi-rect
counsel, so the question was,
the Company state that one of
if you coul-d just
You' l-l have plenty
questions from your
if I can remember, doesn't
the goals of the advisoryt
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(208 ) 890-s198
ANGELL (X)
Idaho Power Company
committee process is
A Yeah,
O Sois
A AsI
advisory process is
particular area with
to support your desired optlons?
so I'l-l- read
that a yes?
stated earlier,the goal of this
to produce
the local
an el-ectric plan for this
jurisdictj-ons that meet
our requirements, desires, obligations for reliable
service and al-so meet the objectives of those local-
communiti-es.
O Would you agree that the community
advisory committee, the CAC, they don't speak for the
residents of Bl-aine County, do they?
A They plan for the residents of Blaj-ne
County.
a They don't speak for the residents of
Blaine County, do they?
A WeII, I think they Iguesslwouldn't
they take on actions for t.hesay they
residents
speak for them, but
of B1aine County and whether you assume that
such actions are speaking on behal-f or not, I guess f 'l-I
l-eave that to you.
O They take on actions on behalf of the
residents of Blaine County?
A That i-s correct.
O Are they e1ected by the residents of25
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CSB REPORTTNG
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ANGELL (X)
Idaho Power Company
Blaine County?
A Yes,
would be members of
elected into office.
O And dld the
Zoning Commission and the
actualJ-y vote
A
o
elected by the
a commissioner and a mayor, which
this committee, are voted on and
to deny the
Blaine County Planning and
Blaine County Commissioners
Company' s application?
They did recently.
And those are the folks who are actually
citizens of Blaine County?
A That is correct, and they had
representation on this advj-sory commi-ttee as we11.
O They were apparently outvoted on the
advisory committee, though.
A No, they werenrt outvoted on the advisory
committee.
O You said the advisory commi-ttee by
majority supported the Company's option.
A Yeah, and that would even incl-ude Bl-aine
County.
O So they were outvoted on the advisory
committee?
A No. f don't understand --
O You said the majori-ty of the advisory
commj-ttee supported the Company's option,' correct?I 25
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(208 ) 890-s198
ANGELL (X)
Idaho Power Company
A They sure did at this time. Back in 2007
and through the process of the advisory committees, we
had consistent support from Bl-aine County and others for
this particular option, and
O Itrs also are you finished?
A Sure.
o
County Board of
conditional use
A
o
committee?
A
o
A
They were.
So
Yeah, let me
Wel1, yeah.
you
the
know, there are
And it's also true, right, that the Blaine
County Commissioners voted to deny your
permj-t application?
Yes, and that was made cl-ear earlier.
And they were a member of your advisory
members from Bl-aine County on
yes, they were in support of the
produced. Now, obviously, going
siting process, the Planni-ng and
the Commissioners at this point
through this particular
Zoning Commission and
in time have found that
advi-sory
electric
committee, and
plan that was
theyrre not
Now, do they
support the
use permit.
o
going to approve a conditional use permlt.
support the electric
electrlc plan, but not
plan? They may stil-l-
approve a conditional
So as between the el-ected Bl-aine CountyI25
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CSB REPORTING
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ANGELL (X)
Idaho Power Company
Board of Commissioners who have voted to deny your
conditional use permit and the citizens advisory group,
which entity do you believe this Commission should give
the most weight to as to whether or not your proposed
your proposal is in the public interest?
A I will just leave it to the Commission to
make their determination upon the body of evidence before
them.
O So the question was, in your opinion,
which entity, your Idaho Power selected community
advisory committee or the duly el-ected BIaine County
Board of Commlssioners, which entity, in your opinion,
should this Commission give the most weight to in making
its public interest finding?
MR. WALKER: Objection. He answered that
exact question.
MR. RICHARDSON: Your Honor, he didn't
answer the question.
MR. WALKER:
doesn't like the answer.
It doesn't matter if he
MR. RICHARDSON: I believe
He answered that question.
he answered the
question that
He's here as
obligation to
the Commissioners wil-1 answer the question.
has the
believe it's
an expert witness. I think
answer the question.
COMM]SSIONER ANDERSON: I
he
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ANGELL (X)
Idaho Power Company
been asked and answered and
Commission is not obligated
I also believe that this
to take any particular
particular partyr so I thinkparty's opinion
you shoul-d carry
over another
OBY
tell- me how fdaho
on with another fine of questioning.
MR. RICHARDSON: Mr. Ange11, can you
Power was able to reduce the estimated
cost of undergrounding the line through Ketchum to zero
when it initially told the community advisory committee
that it would cost several- millions of dol-l-ars to do
so?
A Several mj-11ion dol-lars to do so, meaning
the incremental cost that would be a1l-ocated to the l-ocal
j urisdict j-ons ?
o
undergrounding
A
to underground
a
A
transmission line
the a1l-ocation of
point one or TP1,
Meaning the j-ncremental cost of
the line through Ketchum.
So, again, the cost, the incremental
the line hasn't changed necessarily.
I didnrt hear that.
The
cost,
OSo
j-ncremental cost to underground the
hasn't changed necessarily; however,
those costs wlth regard to transiti-on
that has changed.
the incrementaf costs haven't changed,
so it's stil-l- going to cost severaf million doll-ars to
underground that l-ine through Ketchum; correct?25
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A Thatrs correct.
MR. RICHARDSON: Mr. Chairman, ildy I
approach the wi-tness?
COMMISSIONER ANDERSON: You may.
MR. RICHARDSON: Thank you.
(Mr. Adams distributing documents. )
MR. RICHARDSON: Mr. Chairman, I'm handing
out what has been marked and admitted as Exhibit No. 901
in this proceeding, which was introduced during the
public wj-tness evening earlier, and I would represent
that Exhibit 901- is actually an email- from one of the
members of Idaho Power's community advisory group
committee to my cl-ient Ms. Tidwell.
O BY MR. RICHARDSON: Mr. Angell, would you
take a moment to review this, but l-ook in particular at
the highlighted portion of the l-ast paragraph on page 1.
A Okay.
O Would you agree with the concl-usion of
thls community advisory commi-ttee member that the Company
had to engage in creative financial engj-neering to
justify the cost of undergrounding the l-ine?
A Those are his particul-ar words, not
mine.
O f didn't ask you whose words they were. f
saj-d would you agree
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Idaho Power Company
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A No, I would not agree.
O But you would agree that there are
incremental- costs above those necessary to just build an
overhead transmission l-i-ne; correct?
A Yes, I woul-d agree with that.
O And that those incremental- costs shou1d be
assessed, wouldn't you agree, only against the community
that benefits from the incremental costs of
undergrounding?
A Yeah, incremental- costs above a standard
construction practice would be al-l-ocated to the local
community that, one, reguires the incremental
construction and, two, benefits from it.
O Which community would that be?
A V'Iell, that woul-d be Blai-ne County, City of
Sun Va11ey, and Ketchum, the City of Ketchum.
A So if you underground the line through the
City of Ketchum, is it your posj-tion, then, that Blaine
County and Sun Va11ey shou1d also pay for that
i-ncremental cost?
A Yeah, our assessment is that any customer
that is served from the Ketchum and El-khorn substations
will- receive a reliability beneflt
of a redundant transmission 1ine,
with the construction
and so working with the
around allocatingjurisdictions, we've had dlscussions25
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(208 ) 890-s198
ANGELL (X)
Idaho Power Company
those costs to
al-Iocations of
aren't part of
o
i-n terms of the
A No, the reason
was the initial- effort in
been many years in
looking at overhead
North Valley and we
the process,
a1l- three jurisdictions and, again, the
costs and those particular components
this particular proceeding.
So to be clear, we haven't had
actual costs dropping to zero,
them to?changed who we're allocating
A Epiphany, I'm not sure how that
O We haven't seen the light, have
the cost of this undergrounding process versus
has gone to zero, it's just that werre finding
different way to allocate them; correct?
an epiphany
we've just
we, that
overhead
a
transmissi-on
that the costs have
you can imagine,
and so we started
routes to serve
AS
changed
this has
with
that
also identified an underground
transmission route, and through the process of lookj-ng at
the overhead transmission route, we identifled that the
l-andowners in the Sun Val-l-ey/Xetchum area near Bald
Mountain would not provide any easements and we would
require condemnation to actually build a second line up
in that particular area over Doll-ar Mountain, so we knew
that 1t was going to force us if we were going to go
Dol-l-aroverhead to the doub]e circuit construction across
Mountain, and at that point I indi-cated to the projectt25
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CSB REPORTTNG(208) 890-s198
ANGELL (X)
Idaho Power Company
team that that wasn't acceptable and wouldn't meet the
purpose and need of the project.
After some discussi-ons around that and
also some information about the reluctance of the local
j urisdictions
l-imited local-
knew that we
to pursue l-imited I mean, limited,
improvement districts, excuse me, then we
needed to look at other optlons, and so that
came about the option of the substation, and so we
started inltially with the substation option as building
a substation and underground circuits up into Ketchum and
tying into the distributi-on circuits in Ketchum, and at
first, very high level estimates that looked like it was
a pretty good option cost-wise.
As we refined those costs, those costs
ended up exceeding the underground transmj-ssion l-ine cost
and, also, it would not have the exact same -- woul-dnrt
have as good of performance as the underground
transmission line, and so then we al-so looked at overhead
distribution out of that substation and we identified
that our constructi-on, standard construction, practice of
substations with tie switches was actually a more
appropriate basel-ine compared to an overhead transmission
line that either if it went through Dollar over Dollar
Mountain, it wouldnrt meet the need, because it had to be
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CSB REPORT]NG(208) 890-5198
ANGELL (X)
Idaho Power Company
building overhead through Ketchum was quite the quagmire
there, just
viabl-e, the
not viable, so both of those not being
construction practice that we have that could
be built woul-d be the overhead distribution, and so the
cost of that overhead distribution ended up being the
same amount as the cost of the undergrounding if the
undergrounding were to occur at the Elkhorn Road, so
that's how you get to the zero cost difference.
MR. RICHARDSON: That's all I have,
Mr. Chairman. Thank you, Mr. Ange11.
COMMISSIONER ANDERSON: Sierra CIub, Ms.
Nunez.
MR. NUNEZ: We do not have any
cross-examination questlons .
COMMISSIONER ANDERSON: Thank you.
CoxCom?
MR. ARKOOSH: Thank you.
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CSB REPORTING
(208 ) 890-s198
ANGELL (X)
Idaho Power Company
CROSS-EXAMINATION
BY MR. ARKOOSH:
O Mr. Ange1l, I'm Tom Arkoosh and f
represent Cox Communications and I have a few questions
about the communication aspects. Initially when Idaho
Power proposed to the Blaine County Planning Board, there
was a proposal of two pole heights. Do you recall
that ?
A Yeah, one where it's single circuit
distribution and then double circuit distribution
underneath.
0 And one pole height was tal-l-er than the
other; is that correct?
A Yeah, that is correct.
O And the shorter one was not configured at
that time to carry --
A Thank you, I'm catching up with you. Now,
so there's two yeah, so there are several sections.
Some have single distribution, some have two
distributions, so there's multiple pole heights, but I
think the one you're particularly referring to would be a
pole
pole
height
height
o
with communications attachment point versus a
without communicatlons attachment point.
Correct.t 25
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(208 ) 890-5198
A Okay, I'm with you.
O If you would -- do you have your
surrebuttal testimony in front of you, sir?
A I do, if you'Il give me just a moment.
O If you'd look at page L2, beginning at
l-ine 9 , please, sir .
A I am on page 12, l-ine 9.
O Would you read from l-1ne 9 to the end of
that answer just as a predi-cate to the questions If m
going to ask you subsequently?
A Yes, I wil-l. "As part of Idaho Power's
Blaine County conditional- use permit application, the
Company submitted two different proposed pole heights:
one that conti-nued to allow sufficient room and clearance
f or Cox's facil-ities and a shorter configuration that
for the overheadwould represent
transmi-ssion
the shortest height
overhead 138 kV poles as requested by the
County. As
submitted to
stated in Idaho Power' s Appeal Brj-ef
the Blaine County Board of County
Commissioners,
to devel-op an
Idaho Power has continued to work with Cox
attachment plan that wil-l- al-l-ow Cox to
attach its cable to the shorter transmission po1es.
Accordingly, the ta11er poles submltted as part of the
permitting application are no longer required, only the
shorter poles would be applicable, and could include the25
353 ANGELL (X)
Idaho Power Company
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
pole attachment. "
O And that resolution came about as a result
of negotiations between Idaho Power's engineers and Cox's
engineers; is that correct?
A Yeah, y€s.
MR. ARKOOSH: May I approach with two
exhibits, please?
COMMISSIONER ANDERSON :You may.
documents. )out
Exhibits 701 and 702.
(Cox Communications Exhibit
were marked for identification. )
O BY MR. ARKOOSH: Mr. Angell,
take this in backward numerical-sequence.
Planning
(Mr. Adams passing
MR. ARKOOSH: Mr.
the initial
Chairman, these are our
Nos. 101 & 102
I'm going to
Exhibit 702 is
the proposal before
in Bl-aine County.
A Ido
heights and you'11
communicatj-on pole
Do you see that?
and Zoning Board
Do you recognize that?
0 Okay, and it's got Lwo general pole
note the shorter pole does not carry
the tall-er poJ-e does.attachments, but
I do.
And that was the option initiall-y offered
to the P&Z Board; is that right
A
o
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do
A
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Yes.
you recalI that?
Communications,
And then after
discussions with Cox
Exhibit 101,, that was an exhibit on
of County Commissioners for the CUP
correct ?
o
other utility
A
O
configuratlon
A
if you woul-d
appeal to the
application;
look at
Board
is that
A Yes, I bel-ieve so.
O And the total- pole height of Exhiblt 102
is 52 feet; is that correct?
A I'm sorry, f see a 56.6 and a 61.
O Exhibit 701. I'm sorry, sir, I misspoke.
A Okay, yeah, 47 of the metal steel
structure and another five feet for the insulator to the
top connector.
O And al-l- in all, that is shorter than the
short proposal initially,' is that correct?
A Wel}, you know, this is a different
structure and configuration, but it is shorter than what
is shown on Exhibit 102.
And it has a place for pole attachment for
providers; is that correct?
Yes, it does.
Okay, and is that the current
propounded?
That is the configuration we are proposing
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355 ANGELL (X)
Idaho Power Company
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for this transmission line.
MR. ARKOOSH: Thank you, Mr. Angel1. I
have no further questions, Mr. Chair.
COMMISSIONER ANDERSON: Thank you. City
of Ketchum, Mr. Johnson.
MR. JOHNSON: No questions.
COMMISSIONER ANDERSON: Staff, dhy
questions?
MS. HUANG: Thank you, Mr. Chair.
CROSS-EXAMINATION
you. I
from Mr
BY MS. HUANG:
O Good afternoon,
asked, I think, by Mr. Adams a
3L4, which is an exhibit to Mr.
that exhibit I don't know if
Mr. Ange11. You were
while back about Exhibit
Heckler's testimony, and
you have that in front of
were answerj-ng questions
Heckl-er's dlrect
the initial- pages of the
are requests for
but then there's a
thought you did when you
Adams.
A Yes, I filed it away. f'm trying to keep
organized up here.
O Yes, 1t was in Mr.
testimony, and it's actually not
exhibit, but the very first pages
production No. 1 from Sierra Club,
CSB REPORTING
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ANGELL (X)
Idaho Power Company
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response that's like some preprinted pages about Wood
River-Ketchum 138 kilovo1t l-ine. Do you see that?
A I do.
O AndI
testified about
just wanted to clarify, I
in discussing that Option 1
the Option 2, the shoe-fIy
thought
that saysyou
base thenoption and
A
0 that the differenceyou testify
cost of just
Yes.
did
between those was the
l-ine without the cost of rebuilding
shoe-f1y
Iine?
A No, I believe what Option 2 involves is
rebuilding the existj-ng line, building a shoe-fly 1ine,
removing the shoe-fIy line, and the difference in cost
would then reflect those materials that would be expended
in that build and removal that could not be placed back
used elsewhere.into our stores inventory and
buitding that
the existing
O So what woul-d the cost be to buil-d the
l-ine, including any salvage value that could be
without including the cost of rebuilding the
line?
temporary
recouped,
existing
A Yeah,
Ryan Adel-man may be
particular question.
O Okay,
that in that, in your response
I do not have that information.
better prepared for answering that
I thought I heard you testify about
to Mr. Adams.
CSB REPORTING
(208 ) 890-s198
357 ANGELL (X)
Idaho Power Company
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A Yeah; so what f can describe is that this
was a very high level- initial estimate not including any
sort of right-of-way costs or any of those sort of
acti-vities, permitting and everything. It was kind of
pretty early in the process to identify if we did do a
temporary line construction, you know, what that may l-ook
l-ike and, yeah, I would defer to the project management
experts on those particular costs.
MS. HUANG: Mr. Chairman, may I approach
the witness?
COMMISSIONER ANDERSON: You may.
MS. HUANG: I apologize that I do not have
copies for everyone right now. We'l-l- make copies of this
and provide them. I just would fike it for purposes of
asking the question. I may not need to introduce it, but
I will- make copies for the Commissioners and for al-l- the
parties.
COMMISSIONER RAPER: Ms. Huang, I asked
Matt Evans to make copies, because we need the benefit of
looking at what you're talking about.
MS. HUANG: Okay.
COMMISSIONER RAPER: Thank you, Matt.
MS. HUANG: Thank you, and I apologize for
not having more copies of that already.
0 BY MS. HUANG: But while we are waiting,
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
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tf, Mr. Ange11, you could just look at that and see if
that l-ooks familiar to you.
A Yes, it does look famil-iar.
O Okay, and what that is just while Mr.
Evans is making copies, it is a production response that
I bel-ieve you sponsored
A That's correct.
O during discovery. It was in response
to Sierra Cl-ub production request No. 4.
A Yes.
MS. HUANG: I think we'11 just walt.
COMMISSIONER ANDERSON: And Mr. Morrj-son,
when you whisper with the mic on, we
careful what you whisper.
MS. HUANG: Thank you,
COMMISSIONER ANDERSON :
identifying number on this?
113.
(Staff Exhiblt No.
identiflcation. )
O BY MS. HUANG: In
Sierra CIub asked about the costs
113
hear you, so just be
Matt.
So do we have an
that production request,
we were discussing, the
MS. HUANG: It would be Staff's Exhibit
COMMI SSIONER ANDERSON :Thank you.
was marked for
cost of building the temporary transmission l-ine, taking
CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
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ANGELL (X)
Idaho Power Company
into account recoupment costs for salvage, but not
incl-uding the cost of rebuilding the existing line. Did
you provide a response for the Company about what that
estj-mate might be?
A Yeah, this $4 million number you see
before you, yes.
O Soa
A Yeah,
consistent with over
information and so I
$4 mill-ion amount?
and that woul-d be relatively
the process of time refining
think if you were to look at that
exhibit, what is it, 314
Yes, 3\4, the last two pages.
so in that particular case, when this
particular document was producedr we were looking at
miIlion, and based on some refinement,
closer.
approximately $3.2
yeah, 4 million is
o
A
O Three or
A Again, we
estimate for that. It's
O I also wanted to
four million?
have not done a detailed enough
very preliminary.
permissible to ask
rebuttal testimony
Heckler's rebuttal
A Ido
now, Mr
ask you 1f it's
Heckler offered some
he included this is in Mr.
you
and
at page 6
O Okay. WeI1, I
copy.
reaIly just want to ask
not have aI25
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CSB REPORTING
(208 ) 890-5198
ANGELL (X)
fdaho Power Company
about something that you provided and
recal-l- providing that.
A Okay.
O Mr. Heckl-er summarizes
so tell- me
I'11 ask you if you
a response
or if it
you
doesn'tgave,
sound familiar,
through downtown
about include 50
Does that sound
of the costs that Idaho
if you agree
but that some
Ketchum that
with this
of the costs of siting
Idaho Power is concerned
A
o
to $80r000 for steel- angle structures.
f amil-iar?
Yes.
Would you agree with that, that that's one
Power is concerned about?
Ketchum,
requires
needl-e is reaIIy what
and so it'sdifficult,
sLructures to be able that and they
at doing, quite
all-engineered
are much more
A Yeah, when trying to build through
the route that we have preliminarily 1ooked at
making qulte a few bends and kind of threading a
we would
going
to do
be looking
take someto
expensive than the other structures.
O And does it sound about right that
possibly 12 such
downtown Ketchum?
Art
OSo
high estimate of
structures might be required through
sounds about right.
L2 such structures if we went with the
$80r000, and I did this before, I'm nott
361
25
a math whiz, is about
specific quantifiable
concerned about with
$960,000. Are there any other
amounts that
this siting?
Idaho Power is
I know you discuss in
your testimony a l-ot of the obstacles,
there any other quantifiable amounts?
A Not that f'm aware of at
easements, are
this time. Ryan
Adel-man may be better suited for the questions.
MS. HUANG: I have no other questions.
Thank you.
COMMISSIONER ANDERSON: Thank you.
Commissioners. Commissioner Kjellander.
EXAM]NAT]ON
BY COMMISSIONER KJELLANDER:
O Mr. Ange11, if we coul-d go back to the
40-megawatt planning standard that Idaho Power utilj-zes,
in your testimony today, you said that Lhere's no
specific NERC requirement or standard and that some
utilities are higher and 1ower. I guess I'm wondering
what is that actual range of being higher or lower if
you've seen that through any of your investigation and
research and how did Idaho Power sort of faII into saying
40 megawatts is the magic number with regards to your own
planning standard?
CSB REPORTING
(208 ) 890-s198
ANGELL (Com)
Idaho Power Company
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A Yes; so f would refer you to page B of my
rebuttal testimony where Avista plans so starti-ng on
line 4. Let me know when you're ready.
O lrm ready.
A So Avista plans for a second transmission
line at the threshol-d of 70 megawatts. We've had
dj-scussions with them and they're actually looking to
reduce that particular threshol-d. Rocky Mountain Power,
we actually had two dlscussions. We received an
indication in the neighborhood of 40 megawatts, and then
we've got clarification from them that it's rea11y about
looking at all- the factors simll-ar to what we l-ook at
here to determine where they trigger thelr threshold, so
they're spending a little more, Rocky Mountain is
spending a l-ltt1e more, time establishing that particular
threshold based on more probability analysis, and then,
of course, Northwestern at 20 megawatts, so they're
pretty 1ow. What we did in order to really assess these
values, we contacted members of the Northwest Power Pool
and we actually only received responses from these
individuals. We did not receive responses from any of
the publics.
O Wel-l-, again, then, how did you find your
way to 40 megawatts?
A Yeah, 40 is actually part of the design
CSB REPORTING(208) 890-s198
363 ANGELL (Com)
Idaho Power Company
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plan of Idaho Power's system in that we operate two
voJ-tages for distributj-on, the 34.5 kV and the 12.5 kV,
so L2.5 kV, the circuj-ts that we construct out of there,
you know, capacity-wj-se, they're capable of L2 to 13
megawatts maximum capability, but we limit the operation
to 10 megawatts on each of those, and so we configure for
four 10-megawatt circuits per transformer and so that
kind of starts this concept of re1iability and
redundancy.
The reason we don't l-oad those circuj-ts up
to t2 megawatts j-s if we were to have some sort of outage
and problem in one of those cj-rcuits, we can use those
circuit ties to tie over to the other circuits or other
substations and st1l,1 be able to serve those customers,
so when we get lnto the
substation transformer
substation, so we limit the
size to that 44.5r or 44.8 MVA
sj-ze so that it has some extra capacity. Again, we're
limiting it to 40 and then under emergencles, you know,
we can go above that and use the field ties to cover
other substations, and so
reaI1y well by being able
distribution circui-ts at
the 40, you know, just works
to serve, you know, four
this !2.5 or two at the 34.5 kV
and al-l-ows
reliability
just kind of
us through
that we're
the use of fiel-d ties to have that
desiring to achieve, so rea11y, it
goes from the distribution circuits through
CSB REPORTING
(208 ) 890-s198
364 ANGELL (Com)
Idaho Power Company
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the substation transformer design all the way through our
system.
OI
the 40 megawatts
when there was a
know from your testimony you
played a role in McCall and
need for additional lines,
megawatts been sort of the
utilized?
referenced
l_n
but
Eagle
how 1ong,
roughly, has
your Company
A
40
has
threshold that
I would say ever since I joined the
30 years ago, we've been buying these 44.8's.
kind of the maximum size, so Irm going to say in
of at least 30 years that Irm aware of.
COMMISSIONER KJELLANDER: Thanks.
COMMISSIONER ANDERSON: Commissioner.
EXAMINATION
BY COMMTSSTONER RAPER:
Hi, Mr. Ange1l. Thank you for being here.
Company
That was
the range
O
I'm going to go
Youngblood and
back to, l-ike, the 12 r
point, the standards, in talking
standards, WECC considerations,
il that Mr.
about the NERC
and regarding redundancy
two l-ines for whether
tt S
I establ-ished when I spoke with him a
little bit d9o, but al-so to Commissioner Kjellander's
and the proximity between the
Iike the word or not like the word, and to the point
you
that
CSB REPORTING
(2oB ) 890-5198
36s ANGELL (Com)
Idaho Power Company
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I be1ieve that Mr. Richardson was trying to make and Mr.
Adams to some extent of 100 feet, you know, distance
between the two versus a mil-e-and-a-half between the
l-ines. I think there's a show of a lot of concern
between public and technical- hearing testimony that that
distance, whatever 1t is, close, far, the terrain for
just general, us general people who donrt know all the
aspects that you have articul-ated that landslides, fires,
whatever woul-d impact both lines, but I heard you say
that you are not concerned about those natura1
disaster-type things, in your opinion, and it is your
testimony that those wou1d not impact both l-ines?
A Yes; so l-et me carry along that line a
l-ittle bit further, so the existing transmj-ssion l-iner dS
you can see by the maps, skirts up the valley north and
then at that East Fork Road heads out East Eork and then
up over some mountains to get up to the Elkhorn
substation, so there's some remote terrain that would be
difficul-t to access in the winter. The new transmission
l-ine being buil-t along the highway will always be
accessible, and so one of the things that we're focused
on is it kind of goes, from my mind it goes, back to
property protection and, you know, we coined that
termj-nology at the e-Lab of, you know, reaIIy, the
communlty up there is concerned about these freezing
CSB REPORTING
(208 ) 890-s198
ANGELL (Com)
Idaho Power Company
pipes in those
of conditions,
not going to be
winter conditions, and during those sorts
there I s you know, obviously, fire is
an l-ssue.
Aval-anche woul-d really only take one line
out. You know, the microbursts that we typlcally see, at
l-east that f 've
Company,
spring,
take out
real1y
experienced in my
haven't occurred
fa1l sort of nature where
30 years at the
in the winter, but more
wefve had microbursts
several- lines.
discussed, you know, in
for lcing conditions.
well aware with McCa1l
bome in early and knock
know,
The icing conditions that I
the winter we've had l-ines go out
We also and you probably are
a year ago where we had snowfal-l-
a l-ot of trees over.
This particular transmission line, you
isn't subjected to this sort of tree events that we
see up in
confidence
the McCall area, so Ifve got much more
in this transmi-ssion l-ine where it's located
provj-dJ-ng, you know, quite adequate
of the fact that it's so close, and
structure faj-l-ure, and, again, we're
if there is a structure
reliability because
if we do have a
talking steel
failure, I believe westructures,
can mitigate
O
A
resilience,
pretty quickly.
Which is the resilience?
That's right, and it
and it kind of goes back
goes back to
to that substation,
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ANGELL (Com)
Idaho Power Company
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too. You know, if we do have a problem in the
substation, they are remotely monitored. We wil-l-
configure the substation such that, you know, no single
event in that substation would cause the l-oss of both
those transmission lines from the south going out of
service or transmission l-ines to the north going out of
service, so I see a hiqhly reliable
COMMISSIONER RAPER:
system.
Thank I also
wanted to note that Mr. Arkoosh entered a
you.
piece of
evidence that gave me a little bit to chuckle about in a
very long morning because Idaho Power says, "We shares
our poles. "
MR. ARKOOSH: In that vein, Madam
Commissioner, I forgot to move for the admission of 701
and 102 and I woul-d do so now.
COMMISSIONER ANDERSON: It wil-l be done.
(Cox Communicatj-ons Exhiblt Nos. 701 and
702 were admitted into evidence.)
BY COMMISSIONER ANDERSON:
O I have a quick question, Mr. Angell.
There was a question on Exhibit 4 on the map and I take
you at your word that these l-ines don't cross, but by
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Idaho Power Company
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EXAM]NAT]ON
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CSB REPORTING(208) 890-s198
ANGELL (Com)
Idaho Power Company
Iooking at this, you can certainly understand how there's
a misconception, then, because I see 1j-nes crossing here.
A Understood, and, you know, it does refl-ect
the construction of the new l-ine kind of over the top,
but, yeah, they wil-l- not cross.
O And perhaps you could provide the
Commission
A Oh, sure.
O -- with a map that actua11y, and perhaps
the other j-ntervenors, that shows that more definitively,
because I can understand why the l-ine of questioning went
that way. It looks that way.
A Yeah.
COMMISSIONER ANDERSON: Any other
questions of the Commission? Redirect?
MR. WALKER: No redirect. Thank you, Mr.
Chairman.
COMMISSIONER ANDERSON: Wel-l-, thank you.
Without objection, I belj-eve we can excuse the witness.
MR. WALKER: The witness is excused from
the proceedings?
COMMISSIONER ANDERSON: Without objection.
Hearing none, yes, he is.
MR. WALKER: Thank you Mr. Chairman.
(The witness left the stand. )
COMMISSIONER ANDERSON: When I mentioned
close to the noon hour, T didn't mean a specific time,
but apparently, we're there. We' l-l- take a break f or
Iunch. We'l-l- give ourselves an hour-and-15 minutes,
which will put us at two fet's say 2:15. We are at
TECCSS.
(Lunch recess. )
CSB REPORT]NG(208) 890-s198
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