20170817Hearing Transcript Vol III.pdf

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BEFORE THE IDAHO PUBLIC UTILIT]ES COMMTSSION
IN THE MATTER OF THE APPLTCATION
OF IDAHO POWER COMPANY FOR A
CERTIE]CATE OF PUBLIC CONVENIENCE
AND NECESSITY TO CONSTRUCT
SYSTEM ]MPROVEMENTS FOR WOOD
R]VER VALLEY CUSTOMERS
CASE NO. IPC-E-16-28
BEFORE
COMMISSIONER ERIC ANDERSON (Presiding)
COMMISSIONER KRISTINE RAPER
COMMISSIONER PAUL KJELLANDER
PLACE:Commission Hearing Room
412 West Washington AvenueBoise, Idaho
DATE:August B, 20L7
VOLUME III Pages 371 688
CSB REPORTING
C e rtifrc d S h o rt h an d Rep o rt e rs
Post Office Box9774
Boise,Idaho 83707
[e-mail]
Ph: 208-890-5198 Fax: [phone]
Reporter:
Constance Bucy,
CSR
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CSB REPORTING
(208 ) 890-s198
APPEARANCES
For the Staff:Daphne tsuang, Esq.
Deputy Attorney General-
472 West WashingtonBoise, Idaho 83120-0074
For fdaho Power Company:Donovan E. Tlal.ker, Esq.
Idaho Power Company
Post Office Box 10
Bolse, fdaho 83707-0070
For Leslie A. Tidwell-:RICHARDSON ADAMS, PLLCby Peter iI. Richardson, Esq.
Post Office Box 1278Boise, Idaho 83102
Eor Rock Rolling
Properties, LLC:
R]CHARDSON ADAMS, PLLC
by Gregory M. Adams, Esq.
Post Office Box 1278
Boise, Idaho 83102
For the Sierra Club:KELSEY JAE NUNEZ LLC
by Ke1sey ilae Nunez, Esg.
920 North Clover Dri-veBoise, Idaho 83703
For City of Ketchum:WH]TE PETERSON GIGRAY
& NrcHoLS, PA
by Matthew A. ilohnson
5700 E. Franklin Road
Nampa, Idaho 83587
For Coxcom, LLC:ARKOOSH LAW OFFICES
by C. Tom Arkoosh, Esq.
Post Office Box 2900
Boise, Idaho 83701
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APPEARANCES
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CSB REPORTING
(208 ) 890-s198
]NDEX
WITNESS EXAMINAT]ON BY PAGE
Ryan Adelman
(Idaho Power Company)
Mr. Wal-ker (Direct )Prefil-ed Direct TestimonyMr. Adams (Cross )Mr. Richardson (Cross)
Ms. Haung (Cross)
31]-
3'7 6
399
403
476
N. Vern Porter
(Idaho Power Company)
Mr. WaIker (Direct)
Prefil-ed Rebuttal Testimony
Mr. Adams (Cross )Mr. Rj-chardson (Cross )Ms. Nunez (Cross)
Commissioner Kj ellanderMr. Walker (Redirect)
419
427
45L
464
485
489
492
Guy Cherp
(CoxCom, LLC. )
Mr. Arkoosh (Direct)
Prefiled Direct Testimony
494
491
Michael Heckl-er(Idaho Sierra Club)
Ms. Nunez (Direct)
Prefil-ed Direct Testimony
Prefil-ed Rebuttal Testimony
511
514
56s
Nina Jonas
(City of Ketchum)
Mr. Johnson (Direct)
Prefil-ed Rebuttal- Testimony
Ms. Nunez (Cross)
Commj-ssioner Kj ellander
Commissioner Raper
591
s9B
610
672
614
Michael- Morrison
( Staff )
Ms. Huang (Direct)
Prefiled Direct TestimonyMr. Wal-ker (Cross )
Commissioner Raper
6]-9
627
648
675
David Ange11(Idaho Power Company)
Mr.
Ms.
Ms.
Walker (Redirect)
Nunez (Cross)
Huang (Recross)
679
682
683I25
INDEX
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CSB REPORTING
Wilder, Idaho 8361 6
EXHIBTTS
NUMBER DESCRIPTION PAGE
EOR IDAHO POWER COMPANY:
1 6&8 Admitted 686
7 - Wood River Va1ley Redundant
Electric Service Estimated Cost
Summary
Premarked
Admitted 686
9 Copy of col-or photograph of two
transmission lines
Identified
Admitted
314
686
10 Request & Response for
Productlon No. 18
I dent i fied
Admitted
680
686
11 Request & Response for
Production No. 19
Identi fied
Admitted
680
686
POR THE STAFF:
101 Application of Idaho Power
Company for a CPCN in Case
No. U-1006-89
Premarked
Admitted 686
L02 Order No. 11315 in Case
No. U-1005-89
Premarked
Admitted 686
103 Appllcation of Idaho Power
Company for an amendment to
CPCN in Case No. IPC-E-95-6
Premarked
Admitted 686
104 Letter
dated
from Davld AngeJ-I
1/6/L5
Premarked
Admitted 686
105 Request & Response for
Production No. 2
Premarked
Admitted 686
106 Request & Response for
Production No. 37
Premarked
Admitted 686
107 Request & Response forProduction No. 13
Premarked
Admitted 686t25
EXH]BITS
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CSB REPORT]NG
Wil-der, Idaho 83616
EXHIBITS (Continued)
NUMBER DESCRIPTION PAGE
EOR THE STAFF: (Continued)
108 Order No. 29634 in Case
No. IPC-E-04-4
Premarked
Admitted 686
109 Request & Response to No. 1 Premarked
Admitted 686
110 Request & Response to No. 14 Premarked
Admitted 686
111 Request & Response to No. 6 Premarked
Admitted 686
7L2 Request & Response to No. 5 Premarked
Admitted 686
113 Admi-tted 686
FOR LESL]E TIDWELL:
207 Admitted 686
202 Printout of an articleentitl-ed, Overhead/Underground
Power Lines
Identl fled
Admitted
406
686
FOR THE IDAHO SIERRA CLUB:
301 Request & Response for
Productlon No. 37
Premarked
Admitted 686
302 Request & Response to No. B Premarked
Admitted 686
303 Request & Response for
Productlon No. 1B
Premarked
Admitted 686I25
EXH]BITS
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CSB REPORT]NG
Wil-der, Idaho 83616
EXHf BITS (Continued)
NUMBER DESCRIPTION PAGE
FOR THE IDAHO SIERRA CLUB: (Continued)
304 Request & Response for
Production No. 13
Premarked
Admitted 686
305 Request & Response for
Production No. 8
Premarked
Admitted 686
306 Request & Response for
Production No. 2
Premarked
Admitted 686
307 Request & Response for
Production No. 51
Premarked
Admitted 686
308 Request Nos. 73, 74, 15 & 16 Premarked
Admitted 686
309 Request & Response for
Production No. 7
Premarked
Admitted 586
310 Request & Response for
Production No. 1B
Premarked
Admitted 686
311 Letter from Rebecca
dated 3/10/L5, with
Bundy
attachments
Premarked
Admitted 686
372 Request & Response for
Production No. l-3
Premarked
Admitted 686
313 Artic1e from The Spokesman-Review Premarked
Admitted 686
3L4 Request & Response for
Production No. 1
Premarked
Admitted 686
315 Emergency Power for
Municipalities
Premarked
Admitted 686
316 Emergency Generators Power Town
After Sandy Comes Ashore
Premarked
Admitted 686
3]-7 Idaho Power Company, Goal-s
Document
Premarked
Admitted 686I25
EXHIBITS
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CSB REPORTING
Wil-der, Idaho 83616
EXHfBITS (Continued)
NUMBER DESCRIPTION PAGE
FOR THE IDAHO SIERRA CLUB: (Continued)
318 Request & Response for
Production No. 19
Premarked
Admitted 686
319 Request & Response to No. 14 Premarked
Admitted 685
320 Request & Response to No. 15 Premarked
Admitted 686
327 Idaho Power Company, Goal-s
Document
Premarked
Admitted 686
322 Request & Response for
Production No. 9
Premarked
Admitted 686
323 Request & Response for
Producti-on No. 5
Premarked
Admitted 686
FOR ROCK ROLLING PROPERTIES, LLC:
803 Request & Response for
Production No. 1B
Marked
Admitted
400
400
FOR THE PUBLIC:
901 903 Admitted 686
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EXHIBITS
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CSB REPORTING
(208 ) B9o-s198
ADELMAN (Di)
Idaho Power Company
BOI SE IDAHO TUESDAY AUGUST B 2017 2:L5 P. M
COMMISSIONER ANDERSON: I'11- call- the
proceedings back to order. Continuing with the
Applicant, cal-l- their next witness, Mr. Walker.
MR. WALKER: Thank you, Mr. Chairman.
Idaho Power call-s as its next witness Mr. Ryan Adelman.
RYAN N. ADELMAN,
produced as a witness at the instance
Company, having been first duly sworn
the whol-e truth, and nothing but the
and testif ied as fol-l-ows:
of the Idaho Power
to tell the truth,
truth, was examined
DIRECT EXAMINAT]ON
BY MR. WALKER:
a Could you please state your name and spe1I
your last name for the record?
A Sure, it's Ryan N. Adelman,
A-d-e-I-m-a-n -
O By whom are you employed and in what
capacity?
A Idaho Power Company and Irm the manager ofI25
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CSB REPORT]NG
(208 ) 890-5198
ADELMAN (Di)
Idaho Power Company
the projects
o
group.
Are you
f1l-ed direct
the same Ryan Adelman that
testimony on November Bthpreviously
consisting
A
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of 2l pages?
Yes,
And
Iam
did you
pages ?
al-so fife Exhibit No. 1
consisting of two
A Yes.
O Do you have any corrections or changes or
additions to your testimony or exhibits?
A Yes, I have some additional information
for the Commission on the permitting activities
associated with the conditional- use permit with Bl-aine
County.
O Mr. Adelman, would this be the same type
of update that we heard Mr. Youngblood about the county
permitting process?
A Yes, it is.
MR. WALKER: With the Commissionrs
i-ndulgence, if Mr. Adel-man coul-d give that brief update
on direct.
COMMISSIONER ANDERSON: Please.
THE WITNESS: So it's on page 71 of my
prefiled testimony, continuation of it is after the
referenced hearing on November 1Oth, 20L6, Blaine CountyI25
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CSB REPORTING
(208 ) 890-s198
ADELMAN (Di)
Idaho Power Company
Planning and Zoning Commission held additional pub11c
hearj-ngs on December 1, 2016, and January 5, 2077,
concluding with the denia1 of the application. Idaho
Power appealed the decision to the B1aj-ne County Board of
Commissioners on June 29Lh, 2011. The Bl-aine County
Board of Commissioners reviewed the appeal on August L,
2011, and affirmed Planning & Zoning's decj-sion to deny
the permit.
O
changes or
A
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BY MR. WALKER: Do you have any other
corrections to your testimony?
Do
to the testimony, no.
you have any changes or corrections to
that was prefil-ed?
to Exhibit No. 7, no.
Not
your Exhibit No. 7
A Not
O Okay, and Mr. Adelman, did you bring an
additional exhibit with you here today?
A Yes, I did.
MR. WALKER: Can we approach, please, and
hand this out?
recoqnize that
COMMISSIONER ANDERSON: Please.
(Mr. Youngblood distrlbuting documents. )
BY MR. WALKER: Mr. Adelman, do you
document thatrs just been handed out?
Yes, I do.
And you were present when the Chair of the
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CSB REPORTING(208) 890-s198
ADELMAN (Di)
Idaho Power Company
Commission requested
to be an i-ntersection
fL
an updated drawing of what appears
from Exhibit No. 4 of the two
l-ines; is that what this depicts?
Yeah, this depicts a more zoomed-in
that locatlon the Chai-r had asked aboutperspective of
this morning.
MR. WALKER: Mr. Chairman, pursuant to
request of the Commission to provide thls documentr we
ask that it be marked as Idaho Power Exhibit No. 9.
COMM]SS]ONER ANDERSON: It shall be,
without objection.
(Idaho Power Company Exhibit No. 9 was
marked for identification. )
O BY MR. WALKER: Mr. Adelman, do you have
any other changes, addj-tions, or corrections to your
testimony or exhibits?
A I do not.
O If I were to ask you the questions set out
in your prefiled testimony, would your answers be the
same today?
A Yes, they wou1d.
MR. VIALKER: Mr. Chairman, I move that the
prefiled dj-rect testimony of Mr. Ryan Adel-man be spread
upon the record as if read and that his Exhibit No. 7 and
No. 9 be markedt25
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COMMISSIONER ANDERSON: Seeing no
objections, the testj-mony as described shall be spread on
the record, incl-uding Exhibits 7 and 9.
(The followj-ng prefiled direct testimony
of Mr. Ryan Adelman is spread upon the record. )
CSB REPORTING
(208 ) 890-s198
ADELMAN (Di)
Idaho Power Company
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ADELMAN, DI 1
Idaho Power Company
O. P1ease state your name and business address
A. My name is Ryan Adelman.
is 7227 West Idaho Street, Boise,
O. By whom are you employed
My business address
Idaho 83102.
and in what capacity?
( " Idaho
Proj ect
and
A. I am empJ-oyed by fdaho Power Company
Power" or "Company" ) as the Customer Operations
Manager in the Customer Operations Engineering
Construction Department.
0. Please describe your educatj-onal- background.
A. I graduated in 7996 from the University of
Idaho, Moscow, Idaho, recei-vi-ng a Bachel-or of Scj-ence
Degree in Civil Engineering. I am a registered
professionaf engj-neer in the state of Idaho. I am
currently pursuing a Masters of Business Administration
through Boise State University's Executive MBA program.
O. Please describe your work experience with Idaho
Power.
A. From 2004 to 2008, I was employed by Idaho
Power as an engineer in Power Production's Civ1l
Engineering Group. In 2008, I became an Engineering
Leader responsible for the Langley Gu1ch power plant
project. In 2013, I transitioned to the Civil
Engineering Leader in Power Production. In 2015, T
accepted my current position as Manager of the Projects
Department where I manage Idaho Power's Project
Management and Cost and Controls group.o 25
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ADELMAN, DI 2
Idaho Power Company
O. What is the purpose of your testj-mony in this
proceeding?
A. The purpose of my testimony is to describe the
details of the various options for redundant electrica1
service into the Wood River Valley/North Va11ey area as
provided to me by Company witness David Angell and as
described in his testimony. I will- al-so dj-scuss the
costs, benefits, and detrj-ments of each of the viable
optj-ons and conclude by identifying the l-owest-cost, base
case redundant service option, Overhead Distribution, as
well- as the economically equivalent redundant service
option, Underground Transmission-Transition Point t, for
which the Company is requesting a Certificate of Public
Convenience and Necessity ("CPCN") .
I. BACKGROI'IID
a. Pl-ease state again the construction
configuratj-ons considered by the Company to provide
redundant eLectric servi-ce to the North Val1ey.
A. Idaho Power investigated a number of
construction configurations and numerous routes for
providing a redundant source of energy to the North
VaJ-1ey, lncluding some non-traditional construction
configurations described in Mr. Angellrs testimony. The
Company's analysis concluded that the non-traditional
construction configuration technologies (i.e., microgrid)
for providingt25
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ADELMAN, DI 3
Idaho Power Company
a redundant electric
cost-effective today,
for a relatively short
not eliminate the need
sol-ution are
only provide
energy
would
just not
electric backup
stil-Iperiod of time, and woul-d
for the redundant transmission
system.
Mr. Angel1 described four redundant el-ectrj-c service
constructi-on configuratj-ons whlch all begin with the same
Common Route configuration of a 138 kilovolt ("kV")
overhead transmission line constructed from the Wood
River Transmj-ssion StatJ-on, east to Buttercup Road, then
north along the bike path and Highway 15 to approximately
the area near Owl Rock Road. The four construction
configurations Mr. AngelI described were identified as:
(1) Overhead Transmission, (2) Underground Transmission,
(3) Overhead Distribution, and (4) Underground
Distribution.
O. Which of these construction configurations did
Mr. Ange11 provide to you for additional- analysis and
review?
A. Mr. Angell concl-uded that
Mountain nor the Downtown District
Overhead Transmission construction
neither the Dollar
route options for an
configuration provided
a viable solution for redundant electric service to the
North Va11ey. Mr. Ange11 describes the Companyrs
rationale for eliminating this construction configuration
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ADELMAN, DI 4
Idaho Power Company
The three remaining construction
Ange11 provided for further analysis
identified as:
1. Underground Transuission.
configurations Mr
and review are
The Underground Transmission construction
configuration would incl-ude the Common Route along
Highway 15 to one of three possible
overhead-to-underground transition points between Owl
Rock Road and Elkhorn Road, at which point the
transmission line would be constructed underground and
proceed along the highway and in road rights-of-way to
the Ketchum substation. Please see Angell Exhibit No. 5
2. Overhead Distribution.
The Overhead Distribution construction configuration
would include the Common Route to a new substati-on site
on the west side of Highway'75 south of Owl- Rock Road.
This construction configuration would include a new
substation with 2 x 44.8 MVA L38/1,2.5 kV transformers,
two 4-bay metal-cl-ad
control building, 10
barriers around the
sections, five feeder getaways, a
foot decorative walls, and sound
transformers. Five overhead
distribution circuj-ts woul-d connect with the existing
Ketchum and Elkhorn substation distribution circuits.
Eight sets of padmount
the new substation for
Acquisition
switchgear and optical fiber from
Supervisory Control and DataI25
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(SCADA) control- wiII be installed to effectuate the load
transfers during outages of any transmission Ij-ne or
substation. Please see Angell Exhibit No. 6.
Unlike the Underground Transmission construction
configuration, this option (and the next) only provides
60 megawatts ( "MW" ) of additional service capacity on
f ive distribution circuits. Additional- circuits wil-l-
need to be constructed if the area peak load j-ncreases.
3. Underground Distribution.
The Underground
configuration woul-d
new substation site
Distribution construction
al-so incl-ude the Common Route to a
on the west side of Highway 75 south
the option i-s
Distributi-on
the 72.5 kV distribution
rather than overhead,
landscape work.
of Owl- Rock Road. From this point oD,
substantially the same as the Overhead
construction configuration with
circuits install-ed underground,
requiring boring, asphalt, and
Ir. cosTs, BENEFTTS, AIiID DETRTMENTS
O. What are the estj-mated construction costs for
each of the three viabl-e redundant service l-ine
construction configurations?
A. I have provided Exhibit No. '7, which shows the
cost estimates for each of the three redundant service
construction configurations. The estimates are based on
conceptual design level estimates and al-l- three service
ADELMAN, DI 5
Idaho Power Company
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]ine options include a 30 percent contingency. Variances
could occur as a result of actual right-of-way costs and
underground bore costs.
The constructlon cost estimates for the Underground
Transmission construction configuration range from $29.5
to $36.2 million. The cost estimate ranges depend on the
locati-on of the point of transition from overhead-to-
underground construction. For the Overhead Distribution
construction configuration, the construction cost
estimates range from $29.L to $31.1 million and for the
Underground Distribution constructlon configuratj-on, they
range
line
from $43.4 to $45.9 million. Both distribution
O. What are the benefits and detriments of each of
the three redundant el-ectric service options?
A. The primary benefit of the Underground
Transmission construction configuration is that the line
wou1d provide a second, ful1y redundant transmission l-ine
to the Ketchum substation and reduce sustained outages.
If this option were constructed, the North Valley
customers would not experience a sustained outage for
l-oss of either transmj-ssion l-ine (the exj-sting
transmj-ssion l-ine or the newly constructed transmission
line). Other benefits lncl-ude that the line would support
options lncl-ude basic feeder switchlng automatj-on.
a buil-d-out
The current
demand in the North Valley area of 1,20 MW
peak for thet25
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Idaho Power Company
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ADELMAN, DI 1
fdaho Power Company
North VaIIey is approximately 60 MW. The underground
portion of the transmission line would avoid the City of
Ketchum's Prohibition of Use and greatly reduce the
adverse visua1 impacts that are opposed by many in the
North Va11ey. The l-ine would provide the ability to
de-energize any section of either transmission l-ine for
maintenance, inspection, repair r or reconstruction,
without customer interruption.
O. Are there any potential detriments or downsides
to this option?
A. Yes. Idaho Power does not have historical
experience in constructing and operating underground
transmission. The Company currentl-y does not have any
underground transmission l1ne anywhere on its system, but
underground transmissj-on i-s not new technology and j-s
used by other util-ities in other parts of the country.
O. What are the benefits of the Overhead
Distribution construction configuration?
A. The benefits of the Overhead Distribution
construction configuration are that the combination of
the l-ine, substation, and
provide 60 MW of redundant
customers served from the
distribution circuits woul-d
capacity to the existing
Ketchum and El-khorn
substations, with simil-ar
Underground Transmission
distribution
reliability benefits as the
constructi-on configuration.NewtatrLJ
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ADELMAN, DT B
Idaho Power Company
circuits would provide backup service for maintenance
activities on portions of the existing distribution
circuits. Idaho Power has extensive experj-ence operating
and maintaining overhead distribution lines and
substations.
o.
option?
A.
Are there any possibl-e detriments to this
service caused by the existing
interruption j-n the
transmission 1ine,
customers would experience short sustained outages until-
the distribution ci-rcuits are switched to the alternate
service circuits. This could occur if the current 138 kV
transmission l-j-ne experj-enced a "line eventr" which is an
extended outage for line conductor, j-nsulator, or
structure fai1ures caused by, among other things,
vandalism, incl-ement weather, wood decay, woodpecker
damage, avalanche, fire, and micro-burst wind events.
The Overhead Distribution construction configuration
would not result in a reduction of the number of
sustained outages. The substation and five overhead
feeders woul-d cause additional visual impacts which may
not be supported by the customers in the North Valley
area and may not be al-l-owed by city ordinances in Ketchum
and Sun Va11ey. This configuration provides only 60 MW
of backup service for the existing customers. Over time,additional- facilities would be
Yes. If there was an
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ADELMAN, DI 9
Idaho Power Company
required to maintain backup service as demand in the
North Va11ey area grows.
O. And finally, what are the benefits and
detriments of the Underground Distribution construction
configuration?
A. From a reliability and capacity perspecti-ve,
the Underground Distribution construction configuration
woul-d provide substantially similar benefits as the
Overhead Dj-stribution construction configuration.
However, unlike the Overhead Dlstribution construction
confi-guration, this option would greatly reduce the
visual impacts of overhead distribution circuits and
avoid the city ordinance issues in Ketchum and Sun
VaJ-Iey.
The detriments are similar to that noted for
overhead distribution. It should be noted, however, this
option is the most expensive of al-l three options,
without providing any significant additional- benefits
other than the reduction in adverse visual impacts and
the avoidance of city ordinance issues.
III. CONSTRUCTION CONFIGI'RATIO}I AIIALYSIS
O. Based upon the cost estimates and relative
benefits and detriments of the three construction
configurations, was the Company able to eliminate any
construction configuratj-on from further analysis?I 25
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A. Yes. In reviewing the three proposed
construction configuratlons for providing redundant
electrical service to the North Val1ey, the Company
compared the cost estimates of each option with its
respective benefits and detriments. The Company
concl-uded that the Underground Distribution construction
configuration should be eliminated from further
consideration. The Underground Distribution construction
configuration would provide substantially similar
benefits as the Overhead Distribution construction
configuration, but at a substantially higher cost to
construct. Whil-e there would be fewer obstacl-es to
construction by avoiding city ordinance issues regarding
overhead construction, the significant increase in
construction costs could not be justified.
0. What additional review did the Company perform
for the two remaining service construction
configurations?
A. At this point in the analysis, the construction
cost estlmates for the Overhead Distribution construction
configuration, ranging from i29.1, to $31.1 million,
provide the lowest-cost so1ution to providing redundant
electrical service to the North Va11ey. In addition, the
Overhead Distribution construction configuration is
consistent with the Company's traditional- or standardpractice of providing redundant el-ectric
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ADELMAN, DI 10
Idaho Power Company
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Idaho Power Company
service to an area. However, whil-e the Overhead
Dj-strlbution construction configuration provides an
electrical- sol-ution that would enabl-e the Company to
reduce the duration of sustained outages and continue
providing reliable
the similarity in
electric servi-ce t.o the North ValJ-ey,
costs between the Overhead Distribution
and Underground Transmission construction configurations
necessitated further review between the two. For the
additional analysi-s, the Company used the midpoint of the
for the Overhead Distributionrange in cost estimates
construction configuration ($30 mill-ion) as an economic
base for the Company's standard practice solution. Using
the $30 million economic base, the Company continued
analysis on the range of cost estj-mates for the
Underground Transmissj-on construction configuration.
O. What impact does the 1ocation of the
underground transition structure have on the total-
overall cost estimate for the Underground Transmission
construction conf j-guration?
A. Because the cost of underground transmission is
very expensive, the impact to the overall cost of
providing redundant service to the North Valley under the
Underground Transmission construction configuration is
impacted greatly by the locatlon of the transition point
from overhead to underground transmission. The cost totz5
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construct an underground transmission line can range
between five to l-0 times the costs of overhead
construction. Therefore, the total- project cost estimate
for the Underground Transmissj-on construction
confj-guration can be reduced by continuing the initial-
overhead portion of the Common Route transmission 1ine,
the portion from the Wood River substation in Hailey to
the area near Owl- Rock Road, as far north as possible
before transitioning the line to underground.
O. What options to various overhead-to-underground
transition points were evaluated?
A. Three separate options with varying overhead-
to-underground transition points ( "TP'r ) were analyzed
further. The potential locations for transition points
along Highway 75 are identified as: TP1, near the
intersection of Elkhorn Road and Highway 15; TP2, near
the intersectj-on of Hospital Drive and Highway 15; and
TP3, near the intersection of Owl- Rock Road and Highway
75.
O. V{hat are the total estimated costs for the
Underground Transmj-ssion construction configuration that
are associated with each of these transition points?
A. The overall Underground Transmissj-on project
costs are as f ol-lows:
Underground Transmission-TPL: $30. 0 mil-l-ion
ADELMAN, DI 12
Idaho Power Company
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Underground Transmission-TP2 :
Underground Transmission-TP3 :
$32.1 million
$35.7 million
ADELMAN, DI \2A
Idaho Power Company
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Idaho Power Company
The esti-mates are based on conceptual design l-evel
estimates. Variances could occur as a result of actual
right-of-way costs, underground bore costs, or other
unknown construction-related costs.
O. How do these cost estimates compare to the
economic base case option of $30 million for the Overhead
Dj-stribution construction configuration?
A. The cost estj-mates for options TP2 and TP3 are
greater than the cost estimate of the economic base
construction configuration. However, the cost estimate
for TP1 of $30 million is the same as the cost estimate
for the Overhead Distribution construction configuration.
O. Does the Company consider the Overhead
Distribution base case construction configuration
Underground Transmission-TP1 constructionequivalent to
configuration?
A. From cost basis,
challenges
I
a yes. However, the benefits
and construction are no equivalentt
O. How are the benefits between the two cost
equivalent sol-utions different?
A. Whil-e both the Overhead Distrlbution and
Underground Transmission-TP1 construction configurations
provide redundant service to the North Va1ley area, the
Underground Transmission-TP1 opti-on wil-l- provide
additional- stabj-lity overfuture growth in time as it would al-l-ow for25
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ADELMAN, Dr L4
fdaho Power Company
customer demand. As I stated above, .the Underground
Transmission construction configuration wou1d provide
full redundant capacity of the existing 138 kV
transmissj-on line and would support a build-out demand in
the North Valley area of 120 MW. The l-ine woul-d provide
the ability to de-energize any section of either
transmission line for maintenance, j-nspection, repair, ot
reconstruction, without customer interruptj-on.
While the Overhead Distribution construction
configuratj-on is the economic base case, the Overhead
Distribution construction configuration woul-d provj-de for
only 60 MW
f aci-lities
as demand
of backup
woul-d be
in the
service. Over time, additional
required to maintain backup service
an interruption
North Va1ley area grows. If there was
in the service provided by the existing
transmission line, customers woufd experience short
sustained outages until- the distribution circuj-ts are
switched to the alternate service circuits. The Overhead
Distribution construction configuration would not resul-t
in a reduction of the number of sustained outages.
O. Are there differences in the operational risks
between the two cost-equivalent construction
configurations?
A. Yes. Erom an operating perspective, given the
unlikely event of a 138 kV underground cabl-e fail-ure, DOa25
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ADELMAN, DI 15
Idaho Power Company
customers woul-d experience a sustained outage with the
Underground Transmission construction configuration, as
the existing line will- mai-ntain the continuity of service
untj-l the underground cable is repaired.
For the Overhead Distribution construction
configuration, the potential operational risks include
customers experiencj-ng sustained outages if the al-ternate
source switching is not automated. Even if the switchi-ng
is automated, the customers would experience sustained
outages if any clrcuit is in an abnormal- configuration
prior to the line event. Lack of automation and abnormal-
circuit configurations have the potential- to j-ncrease the
System Average Interruption Frequency Index (SAIFI) and
System Average lnterruption Duration Index (SAIDI)
reliability indices. Additionally, cold l-oad pickup
might complicate and prolong re-energizi-ng feeders that
are out if the automati-on is either not implemented,
disabl-ed, ox malfunctions.
O. Because Idaho Power does not currently have any
experience with underground transmj-ssion facilities on
its system, what does the Company propose to do if there
is a cabl-e failure?
A. As noted above, it is unlikely that the
However, in the event of aunderground cabl-e wil-l fail-.I ttrLJ
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ADELMAN, DI 76
Idaho Power Company
failure, Idaho Power wil-1 util-ize contractors that have
experience
0.
dealing with underground transmission lines.
What construction concerns or challenges did
the Company consj-der between the two cost-equival-ent
options ?
A. Whil-e both opti-ons would require a number of
permits prior to construction, the Company bel-ieves that
construction of the Overhead Dlstribution construction
configuration may be met with considerable resistance.
Blaine County requi-res approval of a conditional- use
permit due to the transmission structure heights. But
the substation for the Overhead Distribution construction
configuration, if l-ocated on the west side of Highway 15,
woul-d also require a site alteration permit of the
Mountain Overlay District from the Bl-aine County Planning
and Zoning Commission. Eor the Underground Transmj-ssion
construction configuration, both the City of Ketchum and
the City of Sun Va11ey require a Right-Of-Way
Encroachment and Dig Permj-t, approved by their respective
city councils. However, there is concern that the
overhead distribution circuits for the Overhead
Distribution construction configuration would likely be
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in specific zoning districts. Through numerous meetings
with city officials,
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Idaho Power Company
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Idaho Power Company
it has become apparent that overhead construction of any
sort will be met with significant resistance.
O. Has the Company thus far pursued any permi-tting
activities for any of the possible routes?
A. Yes. Idaho Power has been and is currently
engaged in acquiring the appropriate and required permits
incl-uding the submission in 201,5 for a right-of-way
encroachment application to the cities of Ketchum and Sun
Va1ley and a conditiona1 use permit, with a revised
application in 20L6 to Bl-aine County. All requests are
still pending, with a hearing set for the conditional use
permit application with Bl-aine County on November 10,
2016.
IV. CONCLUSION
0. Please summarize the Company's analysj-s for
providing a redundant
the North Valley.
A. Across the
source for electrical service in
IdahoCompany's system,
reduce sustai-ned
Power's
and improve
overhead
standard practice
system reliability
transmission lines
outages
or to lmplement dlstribution circuits
with tie switches, particularly in large customer areas
like the North Valley. Two construction configurations
evafuated meet this standard practice criterion, the
Overhead Transmission and Overhead Di-stributionconstruction configurations .
to
is to construct redundant
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ADELMAN, DI 18
Idaho Power Company
Each of the constructlon configurations incl-udes
construction of the Common Router dfl overhead 138 kV
transmission l-ine from the Wood River station to a
l-ocatj-on near the intersection of Highway 15 and Owl Rock
Road. As described in Mr.AngeIIfs testimony, the
Overhead TransmissionCompany determined that the
construction configuration was not a viabl-e option for
the North Va1Iey. This leaves the Overhead Distribution
option, which as the lowest-cost viabl-e construction
configuration serves as the economic base case, dt an
estimated cost of $30 mi11ion, and represents the
traditional- and standard practice sol-ution for providing
redundant electrical service to the North Va11ey.
O. Is the Overhead Distribution construction
confi-guration the Company's recommendation for a CPCN?
A. No. As explained above, the Overhead
Distribution construction configuration wou1d be the
Company's traditional and standard practice for buil-ding
a redundant el-ectrical sol-ution, given 1ts estimated cost
and the constraints of the North Val1ey. Consequently,
it serves as a base case by which to measure any
incremental cost difference that may be requj-red because
of the l-ocaI jurisdictions' preferences. However, the
Company understands and recognizes that the Overhead
Distribution construction configuration may not be theconstructionI25
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configuration desired by many of the constituents in the
North Va1Iey, and has identified the Underground
Transmission-TPl construction configuration as an
economic equivalent to the Overhead Distribution base
case. The Company maintains that if the l-ocal government.
and communities require that the facil-ities be
constructed underground or on a construction
configuration route that increases the cost of such
facilities, the incremental cost difference between the
Overhead Distribution construction configuration and the
underground confj-guration should be assessed to the
cities of Ketchum and Sun Valley and to Bl-aine County.
Company witness Michae1 Youngblood discusses possible
funding arrangements the Company considered for
recovering the j-ncremental- costs of other construction
configurations in his testimony.
O. Is the Underground Transmission construction
configuration an economic equivalent to the Overhead
Distribution construction configuration and, therefore, a
viable option for a CPCN request?
A. Yes. The Companyrs analysis concludes that the
Underground Transmission-TP1 option, at $30 mi11ion,
woul-d be an economj-c equivalent to the Company's standard
practice of providing redundant electrical- service.
Idaho Power views this routing option as striking a
ADELMAN, DI 79
Idaho Power Company
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balance between the Company's obligations to provide
1ow-cost,
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ADELMAN, Dr 19a
Idaho Power Company
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reliable service and the communiti-es' interests.
Consequently, the Company is seeking
Underground Transmissj-on-TP1 route.
Underground Transmj-ssion options, TP2
a CPCN for the
The other
and TP3, result in
If either of
governments or
incremental
mill-ion must be
higher estj-mated costs for construction.
these higher-cost options is chosen by the
communities in the North Va1Iey, then any
costs above the economic base case of $30
funded by the customers in the North Val1ey.
O. Does this conclude your testimony?
A. Yes.
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CSB REPORTING(208) 890-s198
ADELMAN (X)
Idaho Power Company
(The following proceedings were had in
open hearing. )
MR. WALKER: The witness is avail-abl-e for
cross-examlnation.
COMMISSIONER ANDERSON: Thank you. Let's
begin with Mr. Adams.
MR. ADAMS: Thank you, Chair. May I
approach the witness with an exhibit?
COMMISSIONER ANDERSON: You may.
(Mr. Richardson handing out documents. )
CROSS-EXAMINAT]ON
BY MR. ADAMS:
O Good afternoon, Mr. Ade1man.
A Good afternoon.
O lVe're circulating an exhibit that was your
response to Rock Rolling Properties' production request
No. 18 and if admitted, this will be 803. Do you have
that document, Mr. Adams?
A Yes, I do.
O And it says here that you are the sponsor
of this production request at the bottom; correct?
A Yes.
MR. ADAMS: Chair Anderson, I would move25
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CSB REPORTING
(208 ) 890-s198
ADELMAN (X)
Idaho Power Company
to admit this as Exhibit 803.
COMMISSIONER ANDERSON: l{ithout objectlon,
so be it.
(Rock Rolling Properties Exhibit No. 803
was admitted into evj-dence. )
O BY MR. ADAMS: So Mr. Adelman, this
production request asks Idaho Power whether it presented
the shoe-fly temporary option to the Bl-aine County
Planning & Zoning Commission and your response was no.
Do you see that?
A Yes, I
recall talking about
specifically
that option,
and then the
down I don'tput
yes.
Iasto
course, in
part of the
presented;
Right,
subpart b.
transcript
correct ?
A Yeah,
that we discussed it
weII, of
you were unable to identify any
for that body where it was
I mean, part b. asked if we asserted
with Planning and Zoning and we
don't recall doing that.
tl Right;
poi-nt to
so you didn't recal-l- doing it and
you couldn't any part of the transcript where it
was identified as a possible opti-on for the Planning and
Zoning Commission?
A Correct.
O Okay; so the l-ast sentence of subpart a.I 25
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CSB REPORTTNG
(208 ) 890-s198
ADELMAN (X)
Idaho Power Company
here saysr "Reconstruction
temporary shoe-fIy l-ine is
of the existing l-ine
not within the scope
During this proceeding?
Yes, i-n your application.
f donrt have the application in
usang a
of the
that ?Do you see
the scope of the
before the Planning & Zoning Commission is
determined by the application Idaho Power files?
A You could say that, I bel-ieve, y€s.
O And the Company's proposal before the
Planning & Zoning Commission was basical-l-y the same
transmission, overhead transmission, options that are on
the tabl-e here before the Idaho PUC; correct?
A That's correct.
application
A
o
proceedings
o
presenting
discuss the
application?
A
o
A
me.
for those proceedings. "
Yes.
So i-sn't it true that
But isn't it true that in this proceeding
the same transmission opti-ons, the Company did
temporary transmissj-on option in its
front of
a
Mr. Adel-man; so if you turn
it quickly, so in presenting
witness. )
for you,
to page Ll of that and review
the same transmission
(Mr. Richardson approached the
BY MR. ADAMS: We have a copy
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CSB REPORTING
(2oB) 890-s198
ADELMAN (X)
Idaho Power Company
options before this Commission, the PUC, the temporary
transmission l-ine option was discussed, right, but it
says here at about the middle of the page, "The temporary
line woul-d al-most assuredly be deemed a vlsual impact by
many North Va11ey customers." Do you see that?
A Yes.
a Wel-l, doesn't something like a visual
j-mpact of a temporary transmj-ssion line seem more
appropriate to be something that would be decided by the
local- l-and use authorities rather than the Idaho PUC?
A WeII, if we were
other alternative, you know, or
directed to buil-d some
asked
asked as a redundant l-1ne and thatrs
us to provide or
what we went to
Blaj-ne County with. If something changes or asked to,
Bl-aine County would be somethi-ng different most 1ike1y.
0 But they haven't had a chance to take a
look at what you assert to be almost assuredly
problematic visual impacts at this point; correct?
A At this point they have not seen an
application for a temporary Iine, correct.
MR. ADAMS: Okay, thank you. f don't have
any other questions for Mr. Adelman, Chair Anderson.
COMMISSIONER ANDERSON: Thank you, Mr.
Adams. Moving on to Mr. Richardson.
MR. RfCHARDSON: Thank you, Mr. Chairman.I 25
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CSB REPORT]NG(208) 890-s198
ADELMAN (X)
Idaho Power Company
CROSS-EXAMINATION
BY MR. RICHARDSON:
O Good afternoon, Mr. Adelman.
A Good afternoon.
O Let's start with your exhiblt that you
just handed out, number what, 1-0
A Nlne, I believe.
o 109?
COMMISSIONER ANDERSON: Nine.
O BY MR. RICHARDSON: I'l-l-
you that my client's
l-eft-hand corner of
property begins in
that exhibit, so you
just represent to
the upper
can actually see
property there.
Which one of
part of Ms. Tidwel-l-'s
have two red l-ines.
an aerial photo of
On this exhibit, w€
these two red lines is the existing line?
A The existing l-ine starts kind of in the
l-ower l-eft-hand side of the page with structure No. 49!,
Iabeled 491. Moving to the northeast, the next structure
is 492. It crosses the Buttercup Road, it is 493, and
then on up is 494. That is the existing line today.
O So the existing line currentl-y crosses
this street, which I guess is Buttercup Road?
A Yes.
O And it connects to pole 493, and so toI25
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CSB REPORT]NG(208) B9o-s198
ADELMAN (X)
Idaho Power Company
make this construction, you're going to have to
disconnect the existing line and reroute it up Buttercup
Road?
A Under the new configuration, the existing
Ij-ne will be disconnected and reconfigured.
O Are you familiar with the 2073 Beaver
Creek fire that happened in the Sun Va11ey, Ketchum,
Hailey area?
A No, I was not in this group at this
time.
O Pardon me?
A I was not in this group at that time, Do.
Irm not famil-iar with that fire.
O So you have no recol-l-ection whatsoever of
that fire?
A No.
O Do you know if the Company has technology
installed on the existing Viood River-Ketchum line that
locates failures within moments or minutes currently?
A I'm not famil-iar if that's present or
not.
O Do you know if it's on the l-ines that are
comj-ng up from the south to the Wood River substation?
A Again, I'm not familiar whether or not
that is install-ed.I 25
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CSB REPORTING
(208 ) 890-s198
ADELMAN (X)
Idaho Power Company
O Okay. Now, as I
Company's preferred al-ternative
understand it, the
1S
proposed transmission l-ine
correct?
A That's the
through
to underground the
the City of Ketchum;
economic equi-valent to our base
case, Yes.
O And you testify on page 1 of your direct
testj-mony that Idaho Power currently does not have any
underground transmj-ssj-on system -- line anywhere on its
system; correct?
A That's correct.
O And do you have experience with the
j-nstallati-on and maintenance of underground transmlssion
1 ines ?
A Personally, I do not, but representatives
of our Company are becoming more familiar with those,
yes.
o
A
0
underground
prelimj-nary
underground
A
o
So the answer is ilo, you do not?
Me personally, no.
But the Company has studied, hasn't it,
transmission l-ines and at Least done a
compari-son of the costs and effectiveness
versus overhead transmissi-on li-nes?
Yes, I bel-ieve so.
And it is baseline true, isn't it, that
of
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CSB REPORTING(208) 890-s198
ADELMAN (X)
Idaho Power Company
the Company' s preference
transmission lines rather underground transmission
equal?lines, all other things being
A Yes.
MR. RICHARDSON: Mr. Chairman, mdy I
approach the witness?
COMMISSIONER ANDERSON: You may.
(Mr. Adams distributing documents. )
MR. RICHARDSON: Mr. Chairman, I'il handing
out that's not it. Mr. Chairman, I'm handing out an
exhibit, which I'11- ask that it be marked as Exhibit
No. 3 -- 202 for identification purposes, a two-page
exhibit entitled, oD Idaho Power letterhead entitled,
Overhead/Underground Power Lj-nes.
COMMISSIONER ANDERSON z 202?
MR. RICHARDSON: Yes.
(Kiki Tidwel-l- Exhibit No. 202 was marked
for identification. )
O BY MR. RICHARDSON: Mr. Adelman, would you
just take a moment to famil-iarize yourself with this
exhibit, which was actually reprinted from Idaho Power's
website and the web address is reproduced at the bottom.
(Pause in proceedings. )
O BY MR. RICHARDSON: Have you had a moment
to familiarize yourself with Exhibit 202?
is to build overhead
than
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CSB REPORTING
(208 ) B9o-5198
ADELMAN (X)
Idaho Power Company
A Yes.
O So if we reference page 12 of your direct
testimony, you testify that
transmission line can range
times the costs of overhead
be page 72, line 2. Do you
A Yes.
O But isn't it
actually estimated the cost
overhead transmission lines
the cost of overhead Iines,
an underground
five to ten
the cost of
from between
construction, and that would
see that?
true that Idaho Power has
of underground versus
to be between 10 to 20 times
and f'd refer you to the
second bul-l-et the l-ast bul1et on the second page of
the exhibit I just handed you.
A Specific to the project that we're
about here today, the underground costs are flve
tlmes relatively speaking to this project.
O Do you have an idea why they're so
cheaper than Idaho Power's actual- estimate of 10
tlmes? They're, like, half the cost.
A T canrt answer that, I guess.
talki-ng
to ten
much
to 20
O Pardon me?
A I canrt answer that.
O So you don't know if this is just a
particularly easy underground project for the Company?
How long does it take how long does a typicalI25
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underground transmission l-j-ne provide service before it
needs to be replaced?
A Werve been working with a consultant to
help us support the cost estimating for this job on the
underground components and we bel-ieve somewhere between
30 and 40 years.
O According to this ldaho Power document, Lf
you reference the third bull-et on the second pa9e,
they're only expected to last about 20 years; correct?
A That's what the bul-l-et says. f don't know
the source of this information, I guess.
O And then an overhead transmission line can
last as long as 100 years, can it not?
A Potentially the existing line we need to
replace, the existing North Va11ey line, is 55 years old,
I guess.
O Right, but I asked if you an overhead
transmission l-ine can be expected to last as long as 100
years?
A It probably has potential, not necessarily
1i ke1y.
O So in your cost estj-mates on Exhibit 'l ,
did you include the cost of replacing this underground
Iine every 20 years?
A These are the capital installation
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CSB REPORT]NG(208) 890-s198
ADELMAN (X)
Idaho Power Company
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CSB REPORT]NG
(208 ) 890-5198
ADELMAN (X)
Idaho Power Company
costs.
O So thatrs a no?
A No.
O And woul-d you agree that the Company' s
proposal to underground the transmj-ssion line through the
City of Ketchum is based at least in part on
aesthetics ?
A No. Our base option is an overhead
distribution Iine, our base case.
O Right, but yourve chosen not to use your
overhead distribution l-ine and that's partly because of
aesthetics, is it not?
A Therers a lot of discussion I have in my
testimony around the benefits of transmission
distribution al-ternatives, and those are the
reasons why we proposed the TP1 option.
O The undergrounding of the l-ine
over
prr-mary
has nothing
theto do with the impact of an overhead line through
City of Ketchum?
A Absolutely speclfic to your question, the
base case of a distribution alternative relative to the
underground transmissj-on alternative, there are benefits
to go with transmission.
O To go with underground transmission?
A Correct.I
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CSB REPORTING(208) 890-s198
ADELMAN (X)
fdaho Power Company
O And would you refer again to the exhiblt I
just handed out and read the section entitled,
Disturbance and Impact, and that would be on the second
page, if you could read that for the record, please.
A "Underground transmission lines require
large excavations through all habitat types.
Approximately 50- to 80-foot-wide areas are needed to be
cleared for construction and maintenance for the length
of the route for underground l-ines. The right of way
needs to remain free of woody vegetation to prevent
interference to the underground l-ines from tree roots.
Access roads also need to be mai-ntained for underground
l-ines f or maintenance and repair. "
O Does Idaho Power plan to cl-ear and
excavate a swath the entire length of this underground
and B0 feetline through the City of Ketchum between 50
wide?
A We plan on
of way that probably has
existing today.
O And Idaho
existing public right
right-of-way width
uslng the
about that
Power plans
and other vegetation along the entire
underground route through the City of
A Only in the disturbed
a Pardon me?
to clear al-l- trees
length of this
Ketchum?
areas.I 25
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CSB REPORTING(208) 890-s198
ADELMAN (X)
Idaho Power Company
A Only where we plan to disturb.
O And that would be a swath of between 50
and B0 feet widei correct?
A No, I believe our trench widths wil-l
actually be in the neighborhood of 10 to 72 feet wide.
O So the Company doesn't plan to comply with
its own report on overhead versus underground power
Iines, then?
A Werre using our recommendations of our
consul-tant to help support in this.
A Since Idaho Power doesn't have any
underground transmission l-ines on its system, repaj-r
times in the event of an outage would be expected to be
Ionger than repair times on outages on an overhead
transmission l-ine; isn't that true?
A That's true, probably.
O And accordi-ng to this report that I just
handed out as Exhibit 302 [sic]
MR. WALKER: Objection as to the
characterizatj-on as to a report. Hers handed out a
printout from Idaho Power's web
MR. RICHARDSON:
page
r'11 retract the word
"report, " Mr. Chairman, according to Exhibit 302 [sic] .
COMMISSIONER ANDERSON: Very good.
MR. RICHARDSON: Thank you.o 25
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CSB REPORT]NG(208) 890-s198
ADELMAN (X)
Idaho Power Company
O BY MR. RICHARDSON: So if you would read
from Exhibit 302
and Maintenance
lsicl the paragraph entitled, Operations
on page 1-, 1f you could read that into
the record, please.
A "Whil-e underground lines woul-d be }ess
susceptlble to weather-rel-ated outages, for example,
would be morewind, j-ce, fire and
difficult and take
needed, greater
excavate and fix
time constrai-nts are
trees, a cable failure
longer to repair.When repairs are
required to find,
a failure ofthe problems. When
underground equipment does occur, the repai-r times on an
underground cable can be expected to take more than two
weeks per segment of cable, even if a spare duct bank and
material are readily available, whereas repairs on an
overhead segment can be completed much faster."
O So given this, is it reasonable to assume
that it is more expensive to maintain an underground l-ine
than an overhead line?
A fn terms of annual maintenance fees? What
perspective?
O No, in terms of operations and maintenance
generally, which would j-ncur annual maintenance fees,
repairs, upkeep. Is it cheaper or more expensive to
maintain and upkeep an underground line versus an
overhead l-ine?t
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CSB REPORT]NG
(208 ) 890-s198
ADELMAN (X)
Idaho Power Company
ft might be a little bit more, but
speaking, the total cost of the project,
fees are relatively Iow.
So thatfs a y€s, it's more expensive to
underground line?
Yes.
And isn't it true that underground l-ines
than overhead lines?are generally l-ess reliabl-e
A I can't speak to reliability.
an underground l-ine asO So to be c1ear,
A
relatively
maintenance
O
maintain an
opposed to
expensive
requares
length.
between
A
v
an overhead transmi-ssion line is more
to build, has a shorter l-ife expectancy, is
more expensi-ve to repair, takes longer to repai-r, and
B0-foot-wide clear-cut swath its entireup to an
Pretty fair characterization of the distinction
overhead versus underhead -- overhead versus
underground; correct?
A I disagree
just discussed.
O Which one
A The 50- to
with some of the widths you
did you disagree with?
B0-foot-wide swaths.AsI
mentioned before, we're expecting somewhere around L2
feet.
O So with that exception, do you disagree
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CSB REPORTING(208) 890-s198
ADELMAN (X)
Idaho Power Company
A Can you restate your question again?
O So to be cl-ear, dD underground line as
opposed to an overhead transmission line is more
expensive to build, has a shorter life expectancy, is
more expensj-ve to repai-r, and takes longer to repair, and
is generally less reliabl-e than an overhead transmission
l-ine; correct?
A I can't speak to the reliability
component, but the other ones, yes.
O So as an engineer and all- other things
being equaI, I assume your preference would be to build
overhead transmj-ssion lines and not underground
transmission l-ines; correct?
A If it's feasible, yes.
O And in your cost analysis, you only looked
at initial constructj-on costs to make your comparison
with the different options; correct?
A What's presented in
however, when you start looking at
with substations and transformers
the exhibit,Yes i
options
those
the base case
and breakers,
also have shorter life spans
overhead transmission l-ine.
O And for those
line that are more expensive
as l-ife expectancy, repairs,
than the traditional-
costs for an underground
than an overhead l-ine, such
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CSB REPORTING
(208 ) 890-s198
ADELMAN (X)
Idaho Power Company
et cetera,
those extra
woul-d be?
A
costs.
O
who does the Company plan on charging for
costs over and above what an overhead fine
I'm not famil-iar with how we recover our
You're not familiar with how the Power
Company recover its costs?
A Our maintenance costs, yeah.
O You don't know that?
A Not the detall-s.
O Generally, do you know how the Company
recovers costs?
A
O
A
IED.
From whom does it recover its costs?
Primarily our customers.
MR. RICHARDSON: Thank you. Mr. Chairman,
that's al-l- I have
COMMISSIONER ANDERSON: Thank you. Sierra
C1ub, Ms. Nunez.
MS. NUNEZ: We don't have any questions.
Thank you.
COMMISSIONER ANDERSON: Thank you.
CoxCom, Mr. Arkoosh.
MR. ARKOOSH: No questions. Thank you,
Mr. Chairman.25
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CSB REPORTING
(208 ) 8 90-5r_98
ADELMAN (X)
Idaho Power Company
COMMISSIONER ANDERSON: Clty of Ketchum.
MR. JOHNSON: No questions. Thank you.
COMMISSIONER ANDERSON: Staff.
MS. HUANG: Thank you, Mr. Chair.
CROSS-EXAMINATION
BY MS. HUANG:
0 Good afternoon, Mr. Adelman.
A Good afternoon.
O I had asked Mr. Ange11 about some
production response that he gave about concerns with
costs of siting an overhead line through Ketchum. Are
you familiar with costs of siting an overhead l-ine
through Ketchum?
A Yes.
O Mr. Ange11 had testified that there could
be costs of installing steel structures at 50 to $80,000
apiece, about 12 of them. Would you agree with that
testimony that that is a potential cost of siting through
downtown Ketchum?
A That's one, yes.
O Do you know any other quantifiable amounts
of costs that you're concerned about with siting through
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CSB REPORTING
(2oB) 890-s198
ADELMAN (X)
Idaho Power Company
A Other potential- costs that are hard to
quantify are right-of-way costs, the cost for easements
through downtown to be able to maintain our safety
clearances. There wil-l- like1y be signif icant tree
removal through downtown to be able to site a
transmi-ssion l-ine through there. You know, other things
with sight triangles with these large structures at
intersections to have traffic be able to view them,
thatrs a non-quantifiable costr so there are many other
things I can't exactly quantify, but, you know, those
estimates today do not include some of the right-of-way
and easement costs that may be necessary and whether or
not you could even secure them would be another issue.
0 When you say that theyrre hard to
quantify, do
costs ?
A
requests evaluate
don't recal-l off
you have any ball park estj-mate for these
We did through some of the production
property assessed val-ues and it was, I
the top of my head, but I think
somewhere between
or $8 mil1j-on, but
properties through
well-.
O And
property?
the private properties in
did not inc]ude a number
there were 1
of nonprofit
there that would be required as
those are the val-ues of theI25
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CSB REPORTING
(208 ) 890-s198
ADELMAN (X)
Idaho Power Company
A Those are the property values, assessed
values.
0so if you were to have to purchase you're
those you think that cou1d possibly besaying
7to$8
or condemn
mill-ion?
A f can't answer how much it would be, but
it would be substantial- and, again, whether or not you
could even get them at all.
MS. HUANG: Thank you. I don't have other
questions.
COMMISSIONER ANDERSON: Thank you.
Members of the Commi-ssion? Redirect?
MR. WALKER: No redirect, Mr. Chairman.
COMMISSIONER ANDERSON: Thank you. Thank
you very much for your testimony.
THE WITNESS: Thank you, Commissi-oners.
MR. WALKER: Mr. Chairman, may the witness
be excused from the proceedings?
COMMISSIONER ANDERSON: Wlthout objectj-on,
y€S, he may.
MR. WALKER: Thank you.
(The witness l-eft the stand. )
COMMISSIONER ANDERSON: And you may call
your next wj-tness.
MR. WALKER: Idaho Power calls Mr. Vern25
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CSB REPORTING(208) 890-s198
PORTER (Di)
Idaho Power Company
Porter as its next witness.
N. VERN PORTER,
produced as a witness at the instance of the Idaho Power
Company, having been first duly sworn to teII the truth,
the whole truth, and nothing but the truth, was examined
and testif ied as fol-l-ows:
D]RECT EXAMINATION
BY MR. WALKER:
O Cou1d you please state your name and spe11
your last name for the record?
My name j-s Vern
And by whom are
A
0
capacity?
A
president of
Porter, P-o-r-t-e-r
you employed and in what
I'm employed by Idaho Power. I'm the vice
transmission and distribution engineering
and construction and also chief safety
previously
of f i-cer as wel1.
O
testimony in
of 25 pages?
A
o
And did you file rebuttal
this matter on June 23rd, 20L7, consisting
Yes.
Do you have any corrections or changes to
your testimony?I 25
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CSB REPORTING(208) 890-s198
PORTER (Di)
Idaho Power Company
A No, I do not.
o rf
in your prefiled
I were to ask you the questions set out
answers be thetestimony, would your
same today?
A Yes.
prefiled
upon the
MR. WALKER: Mr. Chairman, f move that the
rebuttal- testimony of Mr. Vern Porter be spread
record as if read.
COMMISSIONER ANDERSON: Hearing no
objections, the
the record.
rebuttal testimony shal-l- be spread across
(The foffowing prefiled rebuttal-
testimony of Mr. Vern Porter j-s spread upon the record. )
I 25
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PORTER, REB 1
Idaho Power Company
a. Pl-ease state your name and business address.
A. My name j-s N. Vern Porter and my business
address is L221, West fdaho Street, Boise, fdaho 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 Vice President of
Transmission and Distribution Engineering and
Construction and Chief Safety Officer.
O. Please describe your educatj-onal
A. I am a graduate of Brigham Young
where I received my Bachelor of Science in
Science
background.
University
el-ectrical-
in 1-986. Iengineering in 1985 and Master of
also received my Executive Master of Business
Administration from Boise State University in 2073.
O. Please describe your work experience with Idaho
Power.
A. I joined fdaho Power in l-989 after starting my
career in 1986 with Pacific Gas and Electric Company. I
have held a variety of positions within Idaho Power,
including high voltage transmissj-on engJ-neer, system
planner, technical operations engineer, energy trader,
senior manager of grid operations, senior manager of
customer service, and general manager of power
production. In October 2009, I was named Vice President
of Delivery Engineering and Construction.t 25
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PORTER, REB 2
fdaho Power Company
In December 2013, I was appointed to lead a
Company-wide safety initiative to transform the safety
cul-ture and work with all business unj-ts to improve
safety for employees and the public. In April 2075, I
became the Vice President of Customer Operations, a
position I held
2077, I assumed
Transmission and
Construction and
until- my current
the role of Vice
position. On March l,
President of
Power.
Distribution Engi-neering and
Chief Safety Offlcer for Idaho
the purpose of your rebuttalO. What is testimony
in this matter?
A The purpose of my
issues addressed
rebuttal- testj-mony is to
respond to
the other
in the direct testimony of
parties to this case, particularly those of
Idaho Publ-ic Utilj-ties Commissj-on Staff ("Staff ") witness
Michael Morrison. I will generally address three main
areas i-n my testimony: (1) the significance and
necessity of the Idaho Publ-ic Utilities Commission's
( "Commission" ) determination regarding the need to
provide a redundant l-ine into the North Va11ey in order
for Idaho Power to meet its obligation to reliably serve
the public; (2) the need to reconstruct the existing 138
kilovolt ("kV") transmission line currently serving the
North Va11ey; and (3) the appropriate base case line
route and configuration from which any potentialaddltional incremental- cost isI25
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PORTER, REB 3
Idaho Power Company
calculated and allocated to the local- jurisdictions, if
the Commissi-on determines a redundant l-ine to be
required.
I wil-l- discuss the multiple factors Idaho Power
considered when determining the need for the redundant
transmj-ssion l-ine for the North VaIley and discuss issues
and concerns that were considered when choosing the
proposed route and request for a Certificate of Publ-ic
Convenience and Necessity ("CPCN") .
I. RELIABLE UTILITY SERVICE
O. From your perspective, what is the primary
issue or problem the Company is trying to address and
solve when proposing to construct a redundant 138 kV
transmission line from the Wood River substation, near
Hailey, to the Ketchum substati-on?
A. The primary issue is rel-iabj-lity of el-ectrj-c
service. A long-term power outage caused by the loss of
the single transmission l-ine serving the North Va1Iey,
particularly during extreme weather condi-ti-ons, poses a
risk to the communi-ty that Idaho Power bel-ieves should be
addressed. After considering all avail-able options to
provide adequate reliabilj-ty, the Company has proposed
building a redundant transmission line as the most cost
effective and viable sol-ution to address this reliability
issue. This is consistent wi-th how Idaho Power hasplanned, designed, constructed, and operated its systemt25
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PORTER, REB 4Idaho Power Company
across its service territory, and is consistent with the
prudent electric
confi-guration of
witness David M.
Planning Manager,
planning process
testimony.
practices of system design
expected of the Company in
service to the public?
A. No, Idaho Power
utility design, planning, and system
Powermany other utilities. Idaho
Ange11, Transmissi-on and Distribution
will further discuss the Company's
and util-ity practices in his rebuttal-
O. Have you reviewed the testimony provided by
Staff wi-tness Michael Morrison?
A. Yes. Mr. Morrison ultimately concludes that
there is no demonstrated need for a redundant line,
essentially arguing that the existing radial- l-ine is
sufficiently reliab1e on its own and that it is too
expensive to provide redundant facil-ities.
O. Is this consj-stent with prudent
and the level
utility
of reliability
of essentialits provision
designs its system to meet
certa j-n re1iability and service quality standards. When
certain criteria are met, redundant service is provided
to reduce the risk, cost, and potential damage to the
public from interruption of service or long-term outage.
The North Va11ey area has grown to such a size, is
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and has a substantial seasonal resort economy-that the
risk of harm
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Idaho Power Company
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PORTER, REB 5Idaho Power Company
l-ine to serve the North
from a potential long-term outage and the potential
catastrophic effects of a long-term outage during extreme
winter conditions when North Va1ley el-ectrj-c load peaks
is too great to be served by a single, radial feed-no
matter how rel-iable that single transmlssion line may
have been in the past.
O. What are some of the risks the Company has
one transmissionconsidered if it were to rely on just
Va11ey?
A. The North VaIley's electrical- supply is
mile transmi-ssion line between theprovided by
Wood River
line has a problem that results in an outage, the North
Valley residents and businesses will fose power until the
l-ine is restored. Portions of the l-ine are in rough
terrain and difficul-t to access, especially during the
wi-nter. If the l-ine were to fail- in one of these
difficul-t access areas durj-ng the winter, 1t could take
several days or weeks to restore el-ectrlc service,
jeopardizl-ng public safety, essential services,
businesses, and increasing the potential for extensive
property damage. It is not a questJ-on of Lf , but when
some event (ice loading, avalanche, high winds, fire,
etc. ) will take the l-ine out of service and the North
Va1ley will be without power for mul-tiple days. An event
similar to this described scenario
the L2.4
substati-on and Ketchum substation. If the
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unfolded earlier this year in Jackson Ho1e, hlyoming. In
February, heavy snow and strong winds'toppled L7 steel
power poles supporting the single transmj-ssion line
supplying the resort and local area. Below is a
photograph showing some of the downed structures.
,*
a
ft took five days to restore power. Keep in mind
that the 1-7 poles were easily accessible on flat terrain
as they were directly adjacent to the main road to the
Jackson Hole resort, not up in the mountains, as is the
case wlth portions of Idaho Powerrs transmission line
serving the North Va11ey. The outage disrupted vacation
plans and closed snow-dependent businesses during one of
the area's busiest months.
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fdaho Power Company
O. Have other communities taken comparable
rel-iabil-ity measures j-n constructing redundant
transmission service?
A. Yes. Rel-iabil-ity concerns are not new or
unique to Idaho Power. Idaho Power has instal-led
redundant transmission lines to other mountain
communities that have faced similar issues to provide
adequate service to residents and businesses. In McCall,
for example,
transmission
historically,
line serving
the l-oss of its single 138 kV
the area during hiqh load
outages. Idaho Powerperiods resulted in rotating
successfully worked with the
a second 138 kV line to the
' Park City,a single 46 kV line.
city
McCall-substation. Now that
Utah-served by two 138 kV lines and
Rocky Mountain Power is not
and others to construct
community enjoys a significant boost in reliability that
supports future economic growth and the safety of the
public.
Examples of other area resort-based communi-ties that
are somewhat similarly sj-tuated as the North Valley and
have bu1lt redundant transmission l-ines to support
reliabl-e utility service are:
' Vail-, Colorado-served by redundant 115 kV
lines.
' Aspen, Col-orado-served by redundant 115 kV
Iines.
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Idaho Power Company
capable of serving the entire load after the loss of one
138 kV line and is planning to buil-d an additional 138 kV
line to Park City.
O. Why does the Company believe that it is
necessary to fil-e for a CPCN at this time?
A. After the 2009 Christmas outage, where Wood
River customers were out of power between approximately
11 to 21 hours, Idaho Power met with citizens,
businesses, and city and county l-eaders. The Company
committed that it woul-d move forward on two transmi-ssion
projects identified in the 2007 Wood Ri-ver Electrical
Plan to improve reliability in the area:
1. Reinforce the transmission service to Wood
River substation; and
2. Buil-d a redundant line between Wood
River-Ketchum.
With respect to the
wilt complete the rebuil-d
kV line in 20L7 (originally
Wood River to Ketchum l-ine) .
to rebuil-d the King to Wood
first commitment, Idaho Power
of the King to Wood River 138
built in 7962, dS was the
The Company has been able
River l-ine with the line
the Wood River substation.
savings, improved reliability,
rebuil-d
de-energized
transmi-ssion
This has resulted
due to the existence of a second
line serving
in cost
and enhanced
process when
safety for workers during the
compared to
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PORTER, REB 9
Idaho Power Company
trying to rebui1d the l-ine while energized. This is the
exact same de-energized ability and benefits that woul-d
be available when rebuilding the existing Wood
River-Ketchum line if the proposed redundant Wood
Ri-ver-Ketchum line is in p1ace.
the second commitment, Idaho Powerwirh
has worked
community
develop a
additional-
/ raar-r \\ vrrv L
safety and security to the North Va11ey.
has looked at other al-ternatives (e . g . ,
solar, storage, diesels), but the redundant line is the
Ieast expensive and most viab1e alternative to provide
adequate reliability for al-l- North Val1ey customers.
After all the discussions, meetings, open houses,
and many varying opinions, it is time that a decision is
made on the l-evel of reliabil-ity that Idaho Power is
requi-red to
respect to
with the
leaders,
practical
Communj-ty Advisory Committee
businesses, res j-dences, etc . ,
solution that wou1d provide
to
Idaho Power
provide
of the filing for this CPCN is
and have the Commissi-onthe stakeholders together
about whether the Company's obligation to
as a public utility requires the
a redundant transmission line to the
One
its customers i-n the North Wood River
reasons forVaJ-1ey.
to get
make a decision
reliably serve
construction of
North Val-1ey.I 25
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PORTER, REB 10
Idaho Power Company
Idaho Power believes that, consi-stent with the
prudent planning, design, constructi-on, and operation of
its entire system, its obligation to reliably serve as a
public utility requires the construction of a redundant
transmj-ssion line to the North Va11ey. Whil-e there are
several- parties that
determination, there
disagree with thls
are also numerous
of
f undamental-
parties that
a redundant line.desire and support the construction
If the Commission determines that a redundant line is
required, there
configuration,
redundant }ine,
are significant
routlng, and cost
issues related to the
responsibiJ-ity for that
which I will- discuss later in
this threshofdtestimony. However, there is
the Commission must resolve:
my
issue that
Does the present situation
in the North Va11ey require the construction of a
redundant transmission line in order to mitigate the ri-sk
to public safety, essential services, businesses, and
property damage posed by an extended outage of the
current radia]- transmission service and for Idaho Power
to meet its obligation to reliably serve that portion of
the public? Idaho Power, the CAC, as wel-I as various
businesses and members of the North Va11ey communj-ty,
believe that a long-term power outage caused by the l-oss
of the single transmission line serving the North Va1ley
during extreme weather conditions poses a risk to thet25
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PORTER, REB 11Idaho Power Company
community that
of a redundant
is unacceptable and requires construction
transmission line as proposed.
II. RECONSTRUCTION OF THE EXISTING LINE
O. Are there any probl-ems with the existing line?
A. The existing transmission line, while
historically performing very wel-l-, is aging and needs to
be rebuilt. It was bui1t in 1962 and passes through
mountainous areas that are extremel-y difficult to access,
particularly in the winter months. It is worthy of note
that Idaho Power has maintained the line we11, resulting
in few outages. However, this wood-poIe transmission
l-ine is aging and the risk of fail-ure is increasing-
driving the need to take action. Severa1 structures have
been severely damaged by woodpeckers and some have been
replaced. It is a mistake to assume that because the
l-ine has performed wel-l- in the past that it wil-1 continue
to do sor especially as it ages.
As the line ages, the probability of failure will-
j-ncrease and therefore the Company must rebuild the
existing line. It is important to note that the rebuild
of the existing Line is an independent issue and does not
alleviate the need to buil-d a redundant 1i-ne. The
rebuilt line
capability of
will provide a "reset" on the
Va1ley woul-d stil-l-
losing that single
the existing Iine,'
be exposed to
strength and
the North
and impacts of
however,
the riskI25
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fdaho Power Company
line. In other words, the existing line wil-l- need to be
rebuilt regardless of, and independent of, any
determination as to the construction of a redundant line.
If the proposed redundant line is authorized by the
Commission and constructed by the Company, then the
rebuild of the existing line can be coordlnated with the
redundant line, and completed with litt1e to no
interruption of servj-ce in a much safer manner for work
crews and the public. If the redundant line is not
authorized or constructed, the existing line wj-l-1 stil1
need to be rebuilt. A temporary line will- need to be
constructed to provide service to the North Va1ley whil-e
the existi-ng l-ine is rebuilt, and then removed once
construction is complete. This would resul-t in
significant waster dS the resources used for the
temporary line could alternatj-ve1y be applied to
constructing a permanent redundant solution.
O. Staff witness, Mr. Morrison, recommended that
the Commj-ssion dj-rect the Company to install a temporary
overhead transmission l-ine as necessary to facilj-tate the
repai-r of the existing
with building
transmission 1ine. What issues do
a temporary transmissj-on l-ine and
to the
existing
you
then
see
rebullding the existing Wood River-Ketchum l-ine?
A. As I stated, and as Staff recognized,
regardless of the Commission's determj-nat j-on as
necessity of a redundant transmission li-ne, theI25
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line wil-I need to be rebuil-t. The temporary l-ine option
suggested by Staff j-nvol-ves building a temporary 138 kV
overhead transmissi-on l-ine from Wood River to Ketchum in
a route separate f rom the exj.sting line. This l-ine wou1d
then be energi-zed while the existing l1ne is rebuil-t.
After construction is complete, the temporary l-ine would
be removed. It is estimated the "temporary" line wil-l- be
in place for approximately two years. On the surface
this may appear to be a simple viab1e option, but several
prohibltive issues remaj-n. First and foremost, Idaho
Power's overall objective of achievj-ng adequate
rel-iabil-ity will not be achieved as there would still be
a radial l-ine (albeit new) servi-ng the North Va1ley. The
other prohibitive factor is the same routing barriers
associated with routlng a permanent overhead line through
Blaine County and the city of Ketchum will be present
when attemptlng to route the temporary Iine. Idaho Power
views routing any overhead transmission line through the
city of Ketchum, whether new or temporary, as not viabl-e
for many of the same reasons a permanent overhead
transmission line is not a viabl-e option. fn addition,
the temporary l-ine in the downtown Ketchum area could be
nearly as costly as a permanent overhead l-ine, ds
self-supporting steel poles wil-1 be required due to
street overhang and the numerous angles and turnsrequj-red in the route. Fina11y, Idaho
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PORTER, REB 13
Idaho Power Company
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Power expects the same Iega1 challenges and delays to be
experj-enced as wel-l.
At the end of this process, and after great effort
and expense, the communitj-es in the North Va11ey will be
Ieft in the same compromised reliability situation as
they are today-exposed to the potential rj-sk to public
safety, essential services, and business and property
damage that coul-d result with the loss of the single,
radial transmi-ssion l-ine. Rather than waste resources on
line that woul-d be removeda temporary
makes sense to apply these
and rel-iable
and salvaged, it
resources to a
solutj-on for the North Va1Iey
the redundant transmission line.
Staff stated that
Transmj-ssion options
that may not require
opti-ons because of
efforts and
more permanent
by constructlng
III. APPROPRIATE BASE CASE FOR COST AILOCATTON
O. Staff recommends that if the Commisslon
authorizes the construction of a redundant line that it
"order the Company to consi-der the Overhead Transmission
route through downtown Ketchum as the base case for
determining the cost to be borne by the Company's general
additional- costs ofbody of rate payers, and that any
undergrounding be funded IocaIIy. "1
"the Company has explored Overhead
that are technically feasible, and
easements. The Company rejected these
loca1
PORTER, REB 74Idaho Power Company
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Idaho Power Company
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aesthetic concerns. rr2 Further, Staff was critical of the
Company for sel-ecting the Overhead Distribution routing
and configuration as a base case stating, "the Companyrs
proposed base case appears to be an inadequate,
non-standard alternative used to justify the hiqh cost of
its preferred route."3 Does Idaho Power agree with
Staff's recommendation and comments regarding the
appropriate base case line route and configuration?
A. No. Staff appears to have inappropriately
focused upon aesthetic and visual impact conslderations,
and makes littl-e to no mention of the several other
factors that are consj-dered in selecting an appropriate
base case scenario from which to measure potential
incremental cost i-ncreases attributable to local
jurisdictions. Staff has failed to recognize any
distinction with regard to an overhead 138 kV
transmission l-ine routed through downtown Ketchum in what
is theoretically possible from an engineering perspecti-ve
and what is practical-, feasible, and prudent to route,
permit, construct, and operate.
The Company does not disagree with the general
principles set forth by Staff: That typically overhead
constructi-on of transmission l-ines is the lowest cost,
most predominant method of construction, and that
typically
PORTER, REB 15
fdaho Power Company
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3 Morri-son Direct, p. 20.
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PORTER, REB 15a
Idaho Power Company
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municlpalities or l-ocal jurisdictlons that require
facj-Iities to be 1ocated underground for their own
aesthetic reasons are responsible for the incremental-
cost difference between those facilities and the cost of
overhead construction. However, this is not mandated by
any particular statute,
irrebuttable presumption
customers coul-d never be
or order. There is no
Idaho Powerfs body of
for the cost of
frequently informs
jurisdictions that
for by the local-
downtown Ketchum is
because
ru1e,
that
facilities.
responsi-ble
Idaho Powerunderground
and reminds
such loca1
local- muni-cipal-ities and
requi-rements must be paid
customers and jurisdictions that benefit from them, and
cannot be passed on to the larger body of Idaho Power
customers to pay for. In fact, Idaho Power has informed
North Va1ley residents, specifically including Ketchum,
of this standard and requirement. However, the situation
here is different, in particul-ar, because an overhead 138
kV transmi-ssion l-ine through downtown Ketchum is not a
viable route. As previously stated j-n the Company's
Application, testimony, and discovery responses, an
overhead transmissj-on route through
nej-ther practical nor feasible, and
is not equitable to consj-der this as a ttbase
of this, it
casett for
optj-on is the
distribution
cost determination. The
Company's selected base
configuration for cost
J-east-cost, viabl-e
case of an overhead
PORTER, REB 76
Idaho Power Company
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determinations. The Company's recommended route, that
includes underground transmj-ssion through the city of
Ketchum is cost equivalent to the l-owest cost base case
of overhead distribution, but requj-res extending the
overhead transmlssion portion further north than
recommended by the CAC.
It is important to note that the great majority of
the Company's proposed redundant Line is comprised of the
more typical overhead l-ine construction. The initial- 9.2
miles of the Company's Underground Transmission-TP1
option is overhead 138 kV transmj-ssion }ine from the V0ood
River substation to just outside of the city of Ketchum,
where numerous constraints requi-re a different
configuration for approximatel-y the l-ast two mil-es into
the Ketchum substation.
O. Could the Company's proposal to construct the
138 kV redundant transmission l-inefinal- portj-on
underground be considered "special treatment" for the
Ketchum communj-ty?
A. Staff was critical of the Company, accusJ-ng
Idaho Power of incurring additional and unnecessary cost
simply to provide "aesthetic benefits to the City of
Ketchum. "4 Staff implies that aesthetic considerations
are irrelevant, i-mproper, and inappropriate to even
mention,
of the
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PORTER, REB Lla
Idaho Power Company
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which is not the case. Consideration of visual impacts
is not irrel-evant and is not something special Idaho
Power is doing for the City of Ketchum. It is something
Idaho Power always considers when routing a new Iine,
along with many other considerations.
The Company's proposal j-s a combination overhead and
underground 138 kV transmissj-on project and is the result
of collaboration with the CAC, customers, and city and
county l-eaders. Routing a transmission line through
cities and towns is complex and there is definitely not a
"one-size-flts-a11" approach. When routing a new
transmission line, whether in Ketchum or anywhere efse in
the Companyrs service territory, the Company l-ooks at
many factors, including:
Land use (existing and future)
Right-of-way avail-abi-Ii-ty (publ-ic or
private''": .':.;.1"r:.":":::"::r"'""'" easements
Constructability-topography and terrain
Access during construction and for future
maintenance.
Applicable codes and zoning requirements
Publ-ic perception
Impacts to businesses and homes
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Idaho Power Company
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Visual- j-mpacts and aesthetics
Noise impacts
Radio interference impacts
Safety impacts (c1ose to buildings, big
towers on corners that block visj-on, etc. )
Existing el-ectrical facilities
Existing linear facilj-ties (roads,
railroads, canal-s, trails, etc. )
Natural- resource areas
Man-made obstructions (buiJ-dings, signs,
etc. )
Natural obstruction (vegetation, trees,
1akes, rivers, etc. )
Economics
Schools
Airports and heliports
Military facilities
Shooting ranges (high vandalism)
CulturaI areas
Threatened and endangered species and
habitat
When considering these factors, Idaho Power works
with communities and city/county l-eaders to find the best
route that balances impacts with costs.
PORTER, REB 79
Idaho Power Company
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PORTER, REB 20Idaho Power Company
0. Why is building an overhead 138 kV
transmission l-ine through downtown Ketchum not a
practical or viabl-e so1ution and not appropriate to be
used as the baseline?
A. Typically, the Company looks for ways to build
around a city center and minlmize impacts.
Unfortunately, the Ketchum-Sun Val-l-ey area is in a narrow
valJ-ey and the one option for buil-ding around the city is
already being used by the existing Wood River to Ketchum
lj-ne. Most citles have reasonable routj-ng options where
a ba1ance can be found between impacts and costs. The
North Va11ey does not.
With respect to Ketchum,it is true that an engineer
overhead transmission Iinecould theoretj-ca11y
through the streets,
applicable cl-earance
route an
design long arms that
street. The Company
sidewal-ks and squeeze
But that
and design it so that it would meet
requi-rements. Idaho Power coul-d
put the conductors out over the
could put poJ-es in the middl-e of
energized conductors between
is not a practical sol-ution in thisbuildings.
case. When looking at all the factors the Company
considers when siting a new transmission li-ne, it is
unrealisti-c to try to
Ketchum. It would be
build a new overhead
force an overhead rouLe
simj-l-ar to attempting
transmission line today
to
through
site and
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ldaho Power Company
downtown Boise. It is not reasonabl-e to expect this to
occur because of the impacts, not just visual or
aesthetic, but J-mpacts as a whol-e.
O. As the Vice President of Transmj-ssion and
Distrlbution Engineering and Construction, did you
provide any di-rection to Mr. Angel1 with regard to
pursuing the overhead transmissj-on line option through
the downtown Ketchum corridor?
A. Yes. Idaho Power investigated
the overheadand solutions for contj-nuing
138 kV transmission l-ine all-
portion of the
the way to the Ketchum
substation, including overhead transmj-ssion through
downtown Ketchum. In addition to al-l- of the challenges
of providing an overhead transmission option that are
ful1y described in the Company's Application, Mr.
Ange11's di-rect testimony, and in discovery responses,
Idaho Power considered the ability and probable costs of
securing the necessary easements. Securing easements
through the residential and downtown areas of Ketchum
will- be problematic. The Company believes that it would
be required to condemn property, potentially need to buy
out property, be subject to inverse condemnation claims,
and spend years in court. Idaho Power anticipates these
1ega1 actions will- delay the transmission line pro3ect
for significant periods of time and perhaps indefinitely,
several routes
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and it wou1d be extremely difficul-t to estimate what the
total- cost could be. The ultimate result will be Idaho
Power's inabil-ity to achieve the rel-iabil-ity improvements
needed for the North Va11ey.
The Company believes that it is impractical and not
viable to build an overhead transmission l-ine through
downtown Ketchum. There are too many impacts and the
cost and time (and associated Iega1 challenges) to secure
easements alone make the project infeasible. Staff
references an estimated cost of $18.5 mil-lion for the
downtown Ketchum overhead route option, and it is
important to note that a specific cost estimate was not
developed for the downtown Ketchum portion of this route
as it was deemed to not be viabl-e. A theoretical route
through Ketchum would require the majority of overhead
structures to be a variatlon of a larger steel corner or
dead-end type of structure required to make the numerous
90 degree turns, span buiJ-dings, and support the
esti-mated 72 and 18 foot Davit arms which hold the
insulators and conductors. Generic costs were used for
this portion of the estimate.
The actual cost could be much more and, more
importantly, to determine that cost would require
significant additional engineering and design cost and
investigation, for something the Company determined to
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PORTER, REB 22Idaho Power Company
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not be feasible. Therefore, I instructed Mr. Angell and
his
PORTER, REB 22a
Idaho Power Company
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PORTER, REB 23
Idaho Power Company
team to determine alternative cost-effective solutions
for providing a
VaIIey. Eor al-l-
reliable source of energy to the North
the reasons di-scussed, I did not
consider a 138 kV overhead transmission l-ine through
Ketchum an appropriate or viabl-e basel-ine sol-ution.
Idaho Power believes that the most viable and practical
approach for meeting the electric demands for the
resj-dents of the North Va11ey is with the Companyrs
proposal to construct a 138 kV overhead transmj-ssion line
from the Wood River Transmj-ssion Station, east to
Buttercup Road, then north along the bike path and
Highway 15 to El-khorn Road, at which point the
transmission l-ine wou1d be constructed underground and
proceed along the highway and in road rights-of-way to
the Ketchum substation. Throughout the Company's
testimony, this route has been identified as the
Underground Transmission-TP1 option, and is the solution
the Company views as striking a ba1ance between the
Company's obllgations to provide 1ow-cost, reliable
service and the communities' interests. This is the
option for which the Company is seeking a CPCN.
Idaho Power can provide the North Valley community
the adequate reliability it needs and the Company stands
ready to do its part. Idaho Power respectfully requests
that the Commission issue an order: (1) specifically25
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finding that the present and future public convenj-ence
and necessity requires the construction of a new 138 kV
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PORTER, REB 23a
Idaho Power Company
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transmission l-j-ne and related facilities to provide
redundant transmission service from the Wood River
substation, near Hailey, into the Ketchum substation and
(2) specifically granting the Conpany a Certificate of
Public Convenience and Necessity for the construction of
such line and facilities ldentified in the Company's
Application as Underground Transmj-ssion-TP1. Such
facil-ities are required for Idaho Power to meet 1ts
obligation to reliably provide service in the public
interest, including the portion of that line that must
traverse downtown Ketchum with an underground
l
configuration
O. Does this conclude your testimony?
A. Yes, 1t does.
PORTER, REB 24
Idaho Power Company
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CSB REPORTING(208) 890-5198
PORTER (X)
Idaho Power Company
(The fol-lowing proceedings were had in
open hearing. )
MR. WALKER: The witness is availabl-e for
cros s -examinat ion .
COMMISSIONER ANDERSON: Thank you.
Rolling Rock, Mr. Adams.
MR. ADAMS: Thank you, Chair Anderson.
CROSS-EXAMINATION
BY MR. ADAMS:
O Good afternoon, Mr. Porter.
A Good afternoon.
O Mr. Porter, there's been a lot of
reference here today to the proceedings before the Bl-aine
County Commissioners.
A Uh-huh.
O Were you present representing the Company
at that appeal hearing last week?
A I was.
O So is it true that the Company stated to
the Blaine County Commission that there would be no
i-ncremental costs assigned to the local residents up
there if the transitj-on point one proposal was approved
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CSB REPORTING(208) 890-s198
PORTER (X)
Idaho Power Company
A
the county.
Road, which
hospital, TP2, and
there would be no
Yeah, there were two options presented to
One was to underground there at Elkhorn
is TP1. The other one was back at the
in our proposal-, that is correct, that
incremental- cost to the jurisdictions
for that underground point.
O So was the Company proposing to
for all-
basically
theabsorb those costs, the excess costs,
undergrounding if this Commj-ssion then determined the
base]ine was as
have in front
base case used
A
the Staff has proposed here?
That proposal was based on the
of this Commission at this time,
for cost comparison woul-d be the
proposal
that the
we
underground distributlon option described in the case,
which is equivalent to the cost of the TPI option
undergrounding there at Elkhorn, so that's what that
assumption was based on.
O So then the position presented to the
Blaine County Commission didn't take into account the
possibility that this Commission would determj-ne the
basel-ine was actually much l-ower, around 18, $19 million?
A Say that again.
O Wel-l-, it seems fike your position that you
presented to the county was somewhat inconsistent with
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CSB REPORTING
(208 ) B 90-s198
PORTER (X)
Idaho Power Company
the baseline by this Commission; correct?
A Let me step back a little bit and
l-ittle history here.
jurisdictions about
We began these discussions
give a
with the
as we prepared for
jurisdictions, w€
a TP3 and what those
a year ago or so
this and in
talked about
assumed that
correspondence with
TP1, TP2, and there
incremental costs,
and this was in
the
WAS
costs, those might be and it was
preparation for coming
attempt tohere to prepare for these proceedings and an
come up with some type of a settlement, an agreement that
we could a1.l- work together toward to present to the
Commj-ssion, and so that was based around the assumption
that the base case that we were proposing would be
accepted, So the assumption was underground distribution
option would be the base case al-l the way through. Now,
in that hearing specifically, you know, it didn't come
up, but that underl-ines everything and I think there's a
reasonable assumption that at l-east some of those
Commissioners understand that.
O Understand what?
A What the base
O That they might have been approving
A No, what the base case is and why i-t wou1d
be, the j-ncremental- cost would be, nothing if the
underground distribution case is accepted, then theyt25
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
understand that's the base.
O Are you suggesting they understood that if
they approved your conditional- use permit that
potentially the county resldents woul-d still have been
assigned everything above the $18 million base case?
A Do they understand --
O Are you suggesting that the Blaine County
Commission was aware that there was a risk that the base
case was actually
that the PUC Staff
AIf
would know that.
a
them and it
of; correct?
A
discussJ-ons,
filing this
o
proceeding, this
Because ldaho
the 18 million to $19 million figure
has put forward?
they've read the proceedings, they
But that wasn't in the record presented to
wasnrt anything Idaho Power made them aware
Wel-l-, they wou1d be aware of it from the
the settlement discussions, prlor to even
CASC.
Power's lnitial proposal to
the local jurisdictions was consistent with what the
Staff has stated here; right?
A Initial- proposal when?
O Viel-l-, back before the Company changed its
case, isn't it trueposition to have
that Idaho Power
the TP1 be the base
indicated to the l-ocal- governments thatt25
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CSB REPORT]NG(208) 890-s198
PORTER (x)
Idaho Power Company
any undergrounding would have to be directly assigned?
A You know, this case has been going on for
many years and as Mr. Angell explained, he talked a
littl-e bit about how our thinking on the base case
changed over time as we recognized, for instance, back
at -- when the $18.5 mill-ion was the base case number,
that was based on a base an overhead route across
Dol-l-ar Mountain, which is not viable for this project.
As he explained, j-t's on you have to double circuit
transmission, which defeats the purpose of rel-iabil-ity of
this project, and then there's no way you're going to get
rlght of way to even expand that if you wanted, even if
you wanted, to try to doubJ-e circuit, there's no way
you're going to get rlght of way, so it's not a viable
route, and that changed quite awhile d9o, so they were
made aware of that was true, that was years d9o, but
it's not that way today.
O How many years ago?
A At least a couple.
O A year or two?
A At least.
7\, you
provide
existing
O Okay, Mr.
indicate at l-ine
Porterr on your testimony, page
22 that the rebui]t line will
a reset on the strength and capability of the
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
us right back in the
Company withdrew the
l-ine?
A What
positlon we were in in 1995 when the
prior certificate to build this
it would do
new line, you reset
again, but it does
ri-sk. The risk is
the cl-ock.
not take care
that we have
is obviously with a brand
I mean, you're starting
of the prob1em of the
one single line that
supplies that entire North Valley and it goes through
some pretty tough terrain and it is exposed to all kinds
of elements up there, and if something were to happen,
especj-aIfy up in that area in the wintertj-me above the
East Eork Road, it coul-d be days before we get in there,
and to be able to plow a road in there in the wintertlme
and then get your equipment in there and make repairs, it
coul-d be multiple days, and that kind of a risk j-s pretty
high and the catastrophic i-mpacts to that community would
be substantial, economically, safety, essential services,
public property. There's a l-ot of risk associated with
that single source supplying that entire North Val1ey and
coul-d reset it and that would beso Yes, we
it doesn't solve
we're trying to
O
decades, hasntt
A
heIpfu1, but
which is whatthe problem of redundancy,
sol-ve here.
But that sort of risk has existed for
1t, and the scenario
It has and we've been t.rying to work on25
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CSB REPORT]NG(208) 890-s198
PORTER (X)
Idaho Power Company
it. Since L973 we've been trying to work on it.
O Moving on to page 13 of your testimony,
lines 13 to 27, you're discussing the shoe-fly temporary
line is not viable because it faces the same routing
barriers through the City of
that ?line. Do you see
A Yeah.
O But isn't it true I mean, we've
establ-ished this and don't you agree that the Company
didn't actually propose this temporary line to the
community advisory committee or the Blaine County
Commission, so we don't know for sure whether they woul-d
in fact not prefer the temporary line when the other
option on the table is a permanent redundant line;
right ?
Ketchum as the overhead
A You
is a temporary l-ine
Rebuil-ding the line
know, the option of
is let me say it
l-s a gr_ven.
to rebuil-d
f haven't
what you're saying
this way:
heard anybody
and thesay that we don't need the Iine,
temporary line is simply a way to reconstruct it. Itrs
not an option. You either have you have two options.
You can either have the outages. You can take the North
Va11ey out every time when you're working at replacing
poles, restringing the new conductor, you can take them
out, whlch woul-d be rea1ly unacceptabl-e, or you can build)q.
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
a temporary
that is, but
line while you reconstruct, so thatrs al-l
thatrs a given.
Llke I said before, the purpose of this
case is to tal-k about redundancy and the need for that
and so our proposal to the Blaine County Commission,
Planning & Zoning and then Commission, was the potential-
route for a redundant l-ine. That's what the purpose of
that hearJ-ng was, that whole Planning and Zoning and the
hearing efforts were to route that. It wasn't about
rebuilding the line. V{e know that's goi-ng to happen.
O Okay, and so is it true that the Company
hasn't rea1Iy fuIIy considered the different ways that a
temporary lj-ne could be constructed?
A Repeat that again.
O Is it true that the Company has not fulJ-y
considered and eva1uated the different ways to construct
and implement a temporary l-ine?
A Oh, we've definltely thought about it, how
we coul-d do it and it's challenging. We would have to,
as in the Company's testimonies, we mostly -- we'd have
to build up Highway 75 on a temporary 1j-ne and get
through the downtown district of Ketchum, essentially the
same Ij-ne that we want to construct, essentj-a1ly and
thatrs why it would be challenging to get through the
downtown district of Ketchum, because you l-iterally haveI25
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
to put these
structures,
same designed structures, these steel-
on corners. Just l-ike we talked about with
previous witnesses, you'd have to zigzag
put these big oId towers, these big old
corners and essentially buil-d the 1j-ne,
through town and
structures, on
and then you have
will beto tear it town, and we feel- l-ike
challenges to doing it with that,
money in building that thing and
it doesn't resolve the issue.
there
as well- as the waste of
then tearing it down and
O But we don't have any comprehensive
analysis of those issues in the record, do we?
A I bel-ieve not, except for what we
menti-oned in the testlmony about there will be similar
challenges.
0 So you mentioned the difficul-ties of
weaving it through town, has the Company considered
running the temporary line up to the Elkhorn substation,
which is also connected to the Ketchum substation?
A The temporary line up to the E1khorn
substation?
O Instead of running it through Ketchum.
A The purpose of the temporary line is to
allow you to rebuil-d the existing l-ine. There may be
some you may be able to rebuild the existing l-ine, dt
l-east the portion from Wood River up to E1khorn, wi-th aI25
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CSB REPORTTNG
(208 ) 890-s198
PORTER (X)
Idaho Power Company
temporary l-ine up there, but now you've got to rebuild
the section between Elkhorn
You're not going to go over
hill for that. You're going
town for that.
O fs that something the
and Ketchum substation.
Dol-l-ar Mountain and down the
to have to go around through
Company has fuIIy
that in the
77, you
line
you see
evaluated? Is there any evidence of
record?
A I'm not aware of any of that in the
record, but it's more common sense.
O On your testimony at page 12, l-ine
state that building and then removing a temporary
"wouId result in significant waste, " as opposed to
applying those resources to a permanent l-j-ne. Do
that?
A What lines are you on again?
O Eleven. I paraphrased to a certain
extent.
A Okay, go ahead with your question.
O Okay; so your statement here assumes that
a permanent line is a good thing; correct?
A Absolutely.
0 But that may not necessarily be something
everyone up in the North Va11ey agrees with as we've seen
from the B1aine County Commissj-on. A permanent l-ine is25
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
not necessarily something they want; right?
A You know, I wou1dnrt say that. I woul_d
say, you know, the Blaine County Commissioners, their
discussion, you were there, their discussion was about
that the proposa.l- as written didn't meet the standard for
conditions of approval. Now, we'l-1 wait to see what they
say when they come out with their formal notice to us,
but, you know, we did receive a l-etter, a1so, from the
Blaine County staff talking about some of the j-ssues the
Plannj-ng & Zoning had, and it certainl-y gave us the
indication that with some modifications in certain areas
of the line that it coul-d mean the difference between
approval and disapproval, which in that case before the
Blaine County Commissionersr ds everything was
so we coul-dn'theld to the record in place
dlscuss the agreement we'd
We coufdn't discuss some of these other
modifications that are out there, so we'11 take a l-ook at
it. We'11 see what the Bl-aine County Commission tell-s
usr but we coul-d very well be back working with Planning
and Zoning on some of these modifications to the route
that could possibly make it acceptable, so I woul-d not
characterLze it that Blaine County said they don't l-ike
it. They said the project does not meet the condj-tions
of approval.
at
you
that
know,
time,
reached with Cox Cable.
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O But isn't it true, Mr. Porter, that only
one of the three Commissioners was willing to entertain
remanding your application back to look at
modifications?
A One was very strong and, yeah, absolutely
in arguing that. The other one obviousl-y was not, but
the other one, I'm not sure. What I heard was that it
doesn't meet conditions of approval as proposed.
O Which is basicall-y the same proposal
that's before the Commissi-on, the Idaho PUC, here
today?
A We had two options in with thatr So it had
TP1 and TP2r so j-n other words, undergrounding at Elkhorn
or undergrounding at the hospital.
O Which is the same as you have in your
application here today; correct?
A We have one more. Don't we have TP3 in
this applicat j-on? Maybe not.
O Okay, but you have TP1 and TP2 before both
bodies?
A That is correct. That is correct, thank
you.
O Okay; so back to your statement, you
suggest that materials would be wasted in the
construction of the temporary 1ine. That's what you
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CSB REPORTTNG
(208 ) 890-s198
PORTER (X)
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
said; right?
A Yeah.
O WeII, arenrt materials often wasted in the
process of construction?
A Try not to.
a Coul-dnrt that be considered just the cost
of reconstructj-ng the Iine?
A V0e11, it, obviously, woul-d be a pretty
expensive cost to spend mill-ions of dol-lars on a
temporary line and then throw it away.
O But far l-ess than a fu1ly redundant line
that's permanently there; correct?
A WeI1, obviously, there's cost differences
there, but once again, Lf simpJ-y rebuild theyou
ofdon't get the benefit having two lines.
1ine,
You donrtyou
get
bir.
for Mr
Adams. Mr. Richardson, cross?
the benefit of the redundancy, which is worth quite a
MR. ADAMS: I have no further questions
Porter, Chair. Thank you, Mr. Porter.
THE WITNESS: Thank you.
COMMISSIONER ANDERSON: Thank you, Mr.
MR. RICHARDSON: Thank you, Mr. Chair.
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CSB REPORTING(208) 890-s198
PORTER (X)
Idaho Power Company
CROSS-EXAMINATION
BY MR. RICHARDSON:
O Good afternoon, Mr. Porter.
A Good afternoon.
O You're an electrical engj-neer?
A Yes, I am.
O So you're the kind of guy that drj-ves down
the highway and sees transmissi-on J-ines along the right
of ways and that's a beautiful sight?
A Have you tal-ked to my wife?
O I have not, Mr. Porter.
A She woul-d probably verify that.
O So you told Mr. Adams on cross that you've
been trying to fix this problem, the redundancy problem,
sj-nce L973, but that's not correct, is it, because in
l-995, didnrt the Company say the problem didn't exi-st and
asked the Commission to wi-thdraw its certificate of
convenience and necessity?
A What you said is not true. I don't think
anyone ever said the problem went away. What we said was
that because of siting issues, couldn't agree to a line
route, the .l-ine was they did the assessment, they felt
l-ike it was in good shape, wasn't needed for capacity,
and what f mean by capacj-ty, it wasnrt needed for l-oadI25
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
growth, that we went ahead and withdrew the CPCN.
O Because the line was in good shaper ds you
say?
A At the time, yeah.
O ft wasnrt in bad shape in 1,913, was it?
A Wel-l-, it was 11 years ol-d at the time.
O So it wasn't bad -- you didn't have a
problem in 1973?
A No, but the Company recognized the need
for redundancy, as I've already explained the rj-sks
associated with that. That risk has been out there and
the need to address it has been out there.
O Also, in response to a question from Mr.
from the P&Z staffAdams, you
suggesting
that right?
A
said that you have a
corrections to your
l-etter
application; did f hear
No, what it was was a letter,
we filed our
y€S, that we
received and it tal-ked about appeal and
then a l-etter came in afterwards and talked about some of
the areas of concern expressed by the P6,Z and tal-ked
about with some adjustments that the difference between
acceptable and not acceptable could be taken care of.
O fs that l-etter part of the record here?
A I don't have it, Do, I don't.
0 So it's not part of the record?t 25
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
A I donrt have it here. No, so I don't
think it is part of the record.
A You say a letter came in afterwards. A
letter came in from whom?
A From the Blaine County staff.
O And it was telling you how to fix the
appli-cation so that it would meet the County
Commissioners
A No, it didn't say that. It did not say
that. It simply alluded to that the it was a l-etter
that mentioned these areas of concern from the Planning
and Zonlng that basical-l-y saying 1f you -- with some
adjustments that the dj-fference between acceptabl-e and
unacceptable coul-d be taken care of, something to those
words. I'm not quoting it perfectly.
O Sure, and it's not part of the record, so
we don't know exactly what it says,
A But it was discussed
hearj-ng. As a matter of
specifically brought that
O Of course,
same as the Bl-aine County
fact, one of
up and those points.
these Commissioners are not the
Commissioners; correct?
suggestions in that
wdy, who was the
but
at the BIaine County
the Commissioners
That is correct.
So if you fol-l-owed the
l-etter that you referred to by the
A
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CSB REPORTTNG(208) 890-s198
PORTER (X)
Idaho Power Company
author? Who was it from?
A I can't remember, the Blaine County staff,
though.
O So is it your understanding that if the
Company followed these suggestions to make modifications
to its proposal that the proposal would now be acceptable
to the county?
A It was open. You know, you would have to
work through those type of things. There was no
guarantee. There was no nothing like that. It was
simply saying that there's some areas to work on and with
some tweaks to the or modificatj-ons to your proposal,
it may be acceptable.
O So I assume, correct me if lrm wrong, but
I assume the Company is following up on the invj-tation
from that l-etter to make those tweaks so that the CUP
application can
A
be made acceptable to the county?
Not yet, but, obviously, afl this
of the
j ust
Bl-ainehappened recently and
Commission was
the hearing in front
c]osed to the recordCounty
at the
so we
that existed
time that the P&Z issued their
weren't able to discuss that in
Commissioners at that time, but what
certainl-y consider that and, obviously, consider the
outcome these proceedings and make a decislon what we'11-
determi-nation, and
detail wlth the
we'll- do is we' 1l-
o ac,
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CSB REPORTING(208) 890-s198
PORTER (X)
fdaho Power Company
do but I would assume we'1,1 be back looking at those
make that proposalsuggestions
acceptable
o
and seeing if we can
Make it acceptable to the County
Commissioners?
A Wel-I, the County has their conditions for
approval and those are the things those standards are
what need to be met.
0 So if you're abl-e to take the suggestions
in this letter and make the tweaks that you refer to and
bring this back to the County Commission, do you think it
might make this Commission's decision a littl-e easier i-f
you were able to get the Blaine County Commj-ssion to
approve your conditional use permj-t?
A It may or may not, but the issue in front
of this Commi-ssion is about redundancy, what is the
Company's obligation with respect to the l-evel of service
that we provide the North Va11ey and the Wood River and
that's reaI1y what the main core of this proceeding is
0 Right, I understand
A what l-evel- of re1iability are we needed
to 15a redundant line required.
O And I assume, and correct me if
to the P6,2.
because I haven't seen
tweaks the Planning and
the letter, but I assume
Zoning Commi-ssi-on staff
I'm wrong,
the
suggestedt25
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CSB REPORTING(208) 890-s198
PORTER (X)
Idaho Power Company
to you were to allow
and sti1l comply with
A Their
to solve your redundancy problem
county's concerns.
you
the
focus is
presented to
of that, but
when
does
you
simply on
need is
the project we
them. Obviously,important part
this meet theit's really focused on does
you look at the Planning and Zontng, they're looking
this project meet the conditions for approval.
O Right, but we're talking about the letter
referred to, and that l-etter talked about making
your application; correct?
Correct.
And make
an
changes to
A
nv changes to your application such
acceptable going forward to thethat perhaps it woul-d be
county; correct?
A Potentially.
O And make changes to your application such
that it would be acceptable to the county and acceptable
to meet the Companyrs goa1s,' correct?
A Wel-I, in my mind, obvi-ousIy, the redundant
line is one of the things we feel- is necessary. We
bel-ieve, ds I've explained about the risk, we think it's
an important part of providing relj-able service t.o the
North Valley and sor yes, it would be helpfuI.
O So is the Company plannj-ng on appeal-ing
the denial of the conditional use permi-t or is itI25
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CSB REPORTING(208) 890-s198
PORTER (X)
Idaho Power Company
planning to go down
kind of behind the
A I don't think
behind the scenes. I think
this road of working with the staff
scenes to amend your application?
there would be anything
it would be all wide open.
letter from the Bl-aineWe haven't even received the
County Commissioners yet, so I --
O But it sounds l-ike you're working with the
county staff at least already to make changes.
A No, that letter came in before the
hearing. At this point we're waiting to get that letter
from Blaine County and wer11 see what it says and go from
there.
O So when you were talking with Mr. Adams,
you mentioned several tlmes settlement discussions. Is
that what you're talking about, the settlement
discussions ?
A We mentioned it, but what question do you
have about it?
O I'm asking you where the context of the
settl-ement discussions were taking pIace.
A I would characterlze that as the
discussions we were having with jurisdictions ahead of
this filing to see if we could reach agreement on a
proposal.
O Now, referencing your rebuttal- testimony25
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
on page 18,
impacts is
Idaho Power
that?
A
o
I do see that.
characterLze it
line l, you say that
not irrelevant and is
is doing for the City
consideration
not something
of Ketchum.
of visual
special
Do you see
Yes,
And you were here when Mr. Adelman
testified that Idaho Power has never constructed an
underground transmission l-ine anywhere on its system;
correct ?
A Yeah, that is correct. We do have
underground distrj-bution, a significant amount of it, and
some of those up to the 345 kV underground.
a And you're proposing here to construct an
underground transmj-ssion line through the City of
Ketchum; correct?
A That's correct.
a So Idaho Power is in fact considering
special treatment for the City of Ketchum, j-sn't it?
A f woul-dnrt call it specj-aI treatment. T
would say this is a sol-ution to a problem that we have, a
viabl-e solution that we have is what we have in front
us.
O Vfould you
one-of a-kind treatment
as unique,
Ketchum?for the City of
A It may be I woufdn't maybe to Idahoa25
411
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Power, but certainly not to the utility industry. There
is
O We're st j-cking with Idaho Power here.
Wefre not talking about Pacific Gas and Electric. We're
talking about Idaho Power.
A WeII, I actually worked for Pacific Gas
and El-ectric
O I know you did.
A and I actually have done underground
transmj-ssion. Mr. Adel-man wouldnrt know that, but f have
done it before.
O I appreciate that. Now, can we focus on
Idaho Power?
A Absolutely.
O Thank you. On page 20 of your rebuttal-
testimony, you state that typically, the Company looks
for ways to bui1d around a city center, but the Company
dj-dn't do that for the City of Eag1e, did it?
A You know, I am not an expert on what
happened at the City of Eagle, but I do know there were
options and I know there were options around through
and that's all- about I know, so I probably couldn't
answer any questions you have about
O Have you been on the intersection of State
Street and Eagle Road in downtown Eagle?
CSB REPORTING(208) 890-5198
PORTER (X)
Idaho Power Company
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A I probably have, but I donrt remember
it.
A Whors paying Idaho Power to do the
engineering analysi-s regardi-ng specifically the
undergrounding of the line through the City of Ketchum?
A Who's paying?
o Yes.
A To do the underground analysis?
O Yes.
A At this point in time these costs have not
been approved for recovery, so I would say no one is
paying for it right now.
O Oh, surely someone is paying the bill.
A WeIl, you know, the capital costs of an
underground project, this project has not been submitted
for approva1 at this point j-n time.
O So your engineers that are doing these
studies aren't getting paid?
A Obviously, they're coming out of revenues
from customers, but as far as being able to recover on
those, those have not been approved for recovery at this
point.
O So you wouldn't think it would be prudent
to charge the City of Ketchum to do these studies to
benefj-t specially and uniquely the City of Ketchum to
CSB REPORTING(208) 890-s198
PORTER (X)
Idaho Power Company
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CSB REPORT]NG
(208 ) B 90-s198
PORTER (X)
Idaho Power Company
underground a
A
o
A
under the first heading
offer the al-ternative of
transmission 1i-ne through Ketchum?
Repeat that questj-on.
Do you have Exhibit 202 in front of you?
No, I do not.
MR. RICHARDSON: May I approach the
witness ?
COMMISSIONER ANDERSON: You may.
(Mr. Adams approached the witness. )
COMMISSIONER ANDERSON: I take it you're
going to rephrase your question?
MR. RICHARDSON: I wil-l, Mr. Chairman.
Thank you.
O BY MR. RICHARDSON:
on Exhi-bit
Woul-d you please read
202, "Does Idaho Power
undergroundr " there's
you read that for the
A Isit
instal-l-ing power lines
a third sentence under there, would
record, please?
page 1 or page 2?
It begins, "If Idaho Power were, "
the record, please?
Idaho Power were to receive a
on
o
would you read
A
Page 1.
that for
Yeah, "If
request to bury a proposed transmj-ssi-on line, it woul-d
require advance payment from the requestJ-ng party to
perform a detailed engineering analysis of the project."
You know, I want to make a comment about this. I have noo25
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CSB REPORT]NG
(208 ) 890-s198
PORTER (X)
fdaho Power Company
idea where this came from and how old this document is,
and, obviously, it was out on our website, and I can't
even te11 you with some of the things I'm seeing on
there, I don't know if this is someone from corporate
communicatj-ons that put this together, how stal-e this is,
but, for instance, the 50- to 80-foot-wide areas, I mean,
I don't know where that is coming from, so thj-s
information may be very, very stale, and in the case of
this particular case with Ketchum, getting back to the
options that are availabler we have l-ooked at options to
try to find some way to get an overhead l-ine into Ketchum
and there are just not the options.
This is a it is a unique case, but I
wouldn't cal-l- it special treatment. This is about
where we in most areas you have, you've got ways to
were working through an issueget around, like we just
with Middleton where we were wanting to upgrade a 69 kV
line that goes right down State Street to 138 kV, and we
were able to work with them, because therers options to
put around on the other side of town to make it work. We
don't have those options here in the North Valley. Itrs
very narrow.
It's geographically constrained and it's
unique. We don't have anythj-ng like it in the service
territory, and so I believe that part of the25
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investj-gating the feasibility of underground in this case
is justified. It's unique. The factors j-nvolved in this
are not just aesthetic. Thatrs just one of the many
factors involved in this decision, and so I think it
justifies us taking on that cost to investigate it.
O So let me ask, Idaho Power has not
requested that the City of Ketchum pay for the
engineering analysis for undergrounding the transmission
l-ine through the city; correct?
A No, we havenrt, and it woul-dn't be just
Ketchum, even though itrs undergrounding through Ketchum.
Remember that it's the entire North Valley that's
benefiting from this. ftrs B1aine County. It's the City
of Sun Va11ey. It's Ketchum, also.
O Do you know whether or not it is in fact
Idaho Power's general policy to require the requesting
party to pay for the costs initj-al-l-y of studying the
instal1ation of underground transmission lines when they
make a request to do so?
A I canrt give you a positive answer on
that., because we do get requests al-l- the time to
underground transmission excuse me, distribution, and
so we may very well- request upfront design and those type
of costs from the jurisdictions, but we do have them pay
the incremental amount over the overhead cost what it
CSB REPORTING(208) 890-s198
PORTER (X)
Idaho Power Company
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would have been.
O If you would refer to page 18 over to page
L9 of your rebuttal testimony, you list you provide a
list of by my count 24 different factors the Company
consj-ders when routing a transmission l-ine. Do you see
that?
A Yes.
O Is that an exhaustive l-ist?
A I don't know if I woul-d cal-l- it
exhaustive. I mean, from my experience in designing
transmission and sitting down with our transmission
fol-ks, it's a list we came up with. We may have missed
some, but these are typical type-things you look at when
trying to route a transmission l-ine.
O ftrs pretty comprehensive, though, I would
say.
A But it's true, I mean, routi-ng
transmission is very complex and there's no one size fits
al-I. You've got to consider these type of things. ft's
amazing what you need to cons j-der, whether j-t's 500 kV
out through rangeland with no one around or trying to get
through a city block. Itrs very complex.
O So who's benefitlng by your checking off
each one of these boxes as you evaluate a transmission
project? Is it designed to just make j_t easier for the
CSB REPORTING(208) 890-s198
PORTER (X)
Idaho Power Company
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CSB REPORTING(208) B9o-s198
PORTER (X)
Idaho Power Company
Company to build the line or is it deslgned to minimize
the negative, potenti-aI negative, impacts on the
community?
A I woul-d say neither one. I would say that
you're trying to find the right bal-ance. There are
impacts, there are costs, and therers need, and you're
trying to find the balance that will satisfy those.
O One of the items on your list is
identified as applicable codes and zonj-ng regulations.
Do you see that?
A Yes.
0 Are you actually taking that into
consideration now that the Company's application for a
permit has been denied and its appeal of that decision
has also been rejected?
A It's one of the many factors we consider,
absolutely.
O But it's certainly, apparently according
to the Company, not a decisive factor, is it?
A It's not the decisive factor. Itrs one of
many factors we consider, and as I said before, w€ wil-l
continue to consider Blaine County.
l-ist is theO
business and
Also,
homes,
on your
businesses and homes.
impact to
Do you see
that?I 25
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
A Yeah.
O What does that entail?
A Wel-l-, Iet's say that I wanted to put a
l-et's go to Ketchum where you're zigzagqing through town
and you're putting big ol-d structures on corners creating
safety issues, creating impacts to people that are trying
to get through. If you put a big ol-d tower in front of a
storefront that's a zero setback building and you put a
tower in front of their door, that would have a business
impact on that individual. This is an example.
O And homes?
A If you put it
door, absolutely. You know,
for and one of the challenges
donrt have wide boul-evards.
in front of thelr front
one of the things we
with Ketchum is that
You don't have
look
you
big frontages
it, and sowhere you can put stuff, you just don't have
when you try to ziqzag
it. You've got to put
You've got to put them
1ots. You'veparking
got to
safety
access impacts,
A
through town, you
them right next to
in kind of some of
just can't do
the road.
their impromptu
parks. You rve
like,
got to put
on these corners, which creates
It's not viable.
visual- impacts?
Of tryj-ng to route through downtown
them over
put them,
issues.
O So you have potential safety lmpacts,
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
Ketchum.
O We're talking
and you identified at
about your business and home
impacts
visual,
least safety, access,
anything else you consider?
A Those are all appropriate and I would also
say that when we look to route these, we look for some
room to do so. We look for room. If you l-ook at our
proposed route, it's 9.2 miles of overhead and we feel
Iike we've done a pretty good job. I know it sounds like
we've got to do some adjustments, obviously, according to
Bl-aine County; however, I think we've done a pretty good
of finding a workable solution and we've routed down
Buttercup Road,on Highway 15, and done our best to put
where we already have facilities that arethem in places
already there
segment
O
versus new facilities. There is one
You don't have transmission facil-ities
down Buttercup.
A
facll-ities.
o
down Buttercup
A
0
economics. Do
But there are facilities, distribution
You don't have transmission facilities
Road?
Yeah,
So one
that's correct.
of your other items on your l-ist is
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A Yes, I do.
a And so is that like microeconomics or
macroeconomics? What are you talking about?
A Cost to construct.
O Pardon me?
A Cost.
O Cost to Idaho Power?
A Cost to buil-d it.
O You don't look at economic impacts on the
community, then?
A This is referring to the cost of the
construction of the 1ine.
O So you don't l-ook at the economic impact
on homes and businesses?
A No, not in routing, not in routing
decisions.
a So of all this 24 items all the way down
to do you put a pole in front of somebody's door, you
don't l-ook whether or not you diminish the value of
someone t s home?
A We try to like I said, we're looking
for balance. No, we don't consider the impact on
homes.
O You donrt?
A Yeah.
CSB REPORT]NG(208) 890-s198
PORTER (X)
Idaho Power Company
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OSo
A Excuse me, let me clarify. To answer
specifically your question, the change in property va1ue,
we don't factor that in.
A f didn't ask that questj-on. You don't
look at the impact, your construction of a new
transmission l-ine the impact, oD the value of someone's
home?
A We don't look at that.
O You're more concerned about building a
pole in front of someone's door, but not the value of
their home?
A You know, the way we route, like I said at
the firstr we l-ook for balance, for bal-ance between the
cost, the impact, and the -- what was the third one
and the need for the project, and so as we've routed this
project, I feel we've done a pretty good job of baLancing
those impacts.
a But you said that this l-ist, although not
comprehensive, is pretty exhaustive, so I have to ask if
the decj-sion was affirmatively made by the Company not to
look at the economic i-mpact of property value reductions
along the route of the l-ine.
A You know, we don't do that. We use j-n
most cases, many cases when we can, we use road right of
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PORTER (X)
Idaho Power Company
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CSB REPORTING(208) 890-s198
PORTER (X)
Idaho Power Company
way. Where we need more easements,
them and compensate
I woul-d
and even make the
the va11ey.
O So you
just don't do that, so
we'l-f go out and buy
the use of their
i-n some cases the
l-andowners f or
thatproperty.sdy, a1so,
argument in the North Va11ey that
having a redundant source of energy could be a boon to
said that pretty assertively, we
Company say this may be
it, because you say we
A When you
O Look at
I I 11 ask you,
an issue, but
just do not do
did someone at the
Iet's just ignore
that ?
what do you mean?
impact of the value
transmission line
say "that, "
the economic
of someoners home if you're building a
across their front yard.
A What I'm saying is that we don't go try to
figure out land value or, excuse me, the impact a
transmissi-on
0
my question
ignore that
A
a
No.
Why doesn't
MR. WALKER:
the Company do
Mr. Chairman,
several times
that?
I object. This
and this entire
line might have on someone's property value.
I know, you said that several times, and
is did someone at the Company lnstruct you to
issue?
has been asked and answered
l-ine, the rel-evance at thj-s point is questionabl-e.t 25
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MR . RI CHARDSON : I ' l- l- move oh ,
Mr. Chairman.
COMMISSIONER ANDERSON: Thank you, and I
do want to make a comment that that was asked and
answered and sometimes we don't like the answer, but it
doesnrt change after many times.
MR. RICHARDSON: I appreciate that,
Mr. Chairman.
COMMISSIONER ANDERSON: Contj-nue, please.
MR. RICHARDSON: Thank you,
Mr. Chairman.
O BY MR. RICHARDSON: Assuming the Company's
new transmission line does in fact result in actual
measurabl-e reduction in property values, do you have any
idea who would be responsible for that economic l-oss?
MR. WALKER: Objection, it's askj-ng for a
legal conclus j-on.
MR. RICHARDSON: Itrs hardly a legal
conclusion, Mr. Chairman.
MR. WALKER: He's asking for a 1ega1
conclusion about possible l-iability of property impact.
MR. RfCHARDSON: I didn't ask for a 1egaI
responsibility or 1egal liability.
MR. WALKER: He asked about responsibility
that's beyond the scope of
CSB REPORTING
(208 ) 890-5198
PORTER (X)
Idaho Power Company
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CSB REPORTING(208) 890-5198
PORTER (X)
Idaho Power Company
MR. RICHARDSON: I'm happy to wlthdraw the
question, Mr. Chairman.
COMMISSIONER ANDERSON: f 'm happy to af l-ow
you to.
MR. RfCHARDSON: Thank you. That's al-l f
have, Mr. Chairman.
COMMISSIONER ANDERSON: Thank you,
Mr. Richardson. Sierra Club, Ms. Nunez.
MS. NUNEZ: Yes, thank you.
CROSS_EXAMINATION
BY MS. NUNEZ:
O Good afternoon. Will you please reference
pages 20 through 23 of your rebuttal testimony where you
expJ-ai-n why overhead transmission through downtown
Ketchum was an impractical solution and why you
instructed Mr. Ange11 not to consider it and instead
shift the baseline to overhead distribution? You don't
have to read all- three pages, just bringing you there.
Can you confirm whether this is still your view that j-t's
not real-istic or practical
overhead through downtown
A Absolutely
to route a single 138 kV line
Ketchum?
that's my view. That's the
testimony together, Icase. I even before putting thist25
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
actually went and walked the streets again just to look
again and, flo, itrs not viab1e.
O So at the Company's application at page
21, you describe, not you but the Company describes, the
overhead distributlon option, which is the Company's
baseline as having five overhead distrlbution circuits
that would connect the Ketchum and Elkhorn substation
distribution circuits, so how do you reconcile the
perspective
acceptable,
be?
A
use standard
A couple of things.
construction to do it.
First of aII, I can
I can use standard
that one overhead transmission l-ine is not
but five overhead distribution l-ines would
distribution construction.
can go down and
both of sides of
places.
circui-ts
do. It's
You
We've done it in other
you can see
the road.
distribution
It' son
the need, the
at least the
something we
adequacy
load we have
overhead and it meets
need, to provide redundancy
today. If we need to expand
additional- cost, and anyway,
option, but j-trs overhead.
that, then it will be
it's the least cost viable
It's standard construction.
for
O Is there something substantively different
about the dlstribution lines and the 138 kV transmi-ssion
l-ine that makes one standard and one not and can you
elaborate on that?I 25
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CSB REPORTING(208) 890-s1-98
PORTER (X)
Idaho Power Company
A We1I, there's
distribution and transmission
dj-stribution is L2,500 volts
a huge difference between
construction. Your
versus 138r000 vol-ts, so in
size, it's huge,
can route it on a
and f can take a distributlon line and f
right
that
of way and put it about
anywhere. You can't do with transmission.
Transmission is much It requires more space/
more safety concerns,type
two.
of things. There's a
road
bigger.
those
big difference between the
0 Okay, thank you. I just have one more
question. Tal-king about the temporary shoe-f1y line
al-ternative or option for construction, did the Company
consider the possibility that the temporary shoe-fly l-ine
might run into the El-khorn substation and then by
upgrading the interconnections on the existing
distributi-on circuits between Ketchum and El-khorn that
that might allow rebuilding the existing 138 kV line
without all- the difficu1ties of trying to sj-te through
downtown Ketchum?
A f can't answer that for sure if we did
that. I know we've done some studi-es on that. I know
that underground -- to get to Elkhorn we'd have to it
woul-d probably require some undergrounding as wel-I and so
we'd be right back to the same situation of
undergrounding. Then you get to Elkhorn and you've onlyI25
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CSB REPORTING
(208 ) 890-s198
PORTER (X)
Idaho Power Company
got two boy, f'm
one that coul-d tell-
come out of Elkhorn,
not sure. Dave AngeJ-I would be the
us how many distribution cj-rcuits
but you'd be bullding all those
circuits out to, once again, tie into the Ketchum
circui-ts. It may even be a worse situation, but
have a lot of detail on that one.
O That hasn't really been thoroughly
I don't
analyzed yet?
A It may have been.
MS. NUNEZ: Okay,
Dave Angel1 woul-d know.
thank you. No further
questions.
COMMISSIONER ANDERSON: Thank you.
CoxCom, Mr. Arkoosh?
MR. ARKOOSH: No questions. Thank you,
Mr. Chairman.
COMMISSIONER ANDERSON: Thank you. City
of Ketchum, Mr. Johnson?
MR. JOHNSON: No questions.
COMMISSIONER ANDERSON: Thank you.
Staff.
MS. HUANG: I have nothing.
COMMTSSfONER ANDERSON: Thank you.
Commissioner Kj e1lander.
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CSB REPORTING
(208 ) 890-s198
PORTER (Com)
Idaho Power Company
BY COMM]SS]ONER KJELLANDER:
probably
kind of
O He11o,
answered this
EXAM]NATION
and hopefully, I know you've
severa1 different ways, but I
want to can
j ust
kindhear it maybe
around it, so I
one more time so I
apologlze if it's
put it together.
of get my
something
get there
I recall
you've already sort
arms
if I can.
It sounds
like I coul-d piece it together, but I just want to try to
With that long preface, 1et's try.
from the City of Eagle case, the circumstances
city through its comprehensive plan
corridor down a pretty sizeable a11ey
town, so it already had transmission
but there was this identified corridor
there was that the
had establ-ished a
that went through
Ij-nes through it,
through
Ea91e.
correct?
town that was
Nothi-ng like
pretty much a
that exists in
straight
Ketchum,'
shot through
is that
A That's correct.
O okay; so as you l-ook to try to put
together your cost comparisons and what might be a base
p1an, you start to factor in things like safety that
essentlally say if I
there's a good chance
itself around there,
put this too cl-ose to a corner,
I'm going to have
maybe somebody who
a vehicle wrap
doesn't get seen25
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as a pediatrician or a bike just shoots out, you don't
see it until itrs too 1ate, a l-ot of safety factors and
that's some additional liabil-ity concerns in a city like
Ketchum; is that correct?
A Yeah, that is correct. I would even add
on to that it's even cars pulling out canrt see around
the i-ntersection. We've made those mistakes before and
had to back off, pole structures back off corners.
O And it's kind of hard to put a cost on
that to quantify what that is.
A Yes.
O Okay; so Irm going to ask you to do that.
If you cou1d create a base case that took the same route
as this TPl, but instead of having the underground part,
it was all overhead based on al-I those things, what would
this broad range of that base case l-ook like in terms of
the comparison of costs to the TP1 as it sits today i-n
your application that includes the underground piece?
A Great questi-on. I've thought about this a
little bit. I havenrt done any -- penciled out any
numbers or anything like that, but my personal opinion j-s
that I think it woul-d be more expensive and, in
particular, for the right-of-way acquisition. I think to
acquire f don't even know if we could get that right
of way. As you talk to our customers there who woul-d be
CSB REPORTING
(208 ) 890-s198
PORTER (Com)
Idaho Power Company
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CSB REPORTING
(208 ) 890-5198
PORTER (Com)
Idaho Power Company
impacted, they make it very cl-ear to us that they would
oppose it to the very nth degree and wilJ-ing to lawyer up
and those types of things, and so you just see that
it's I donrt think you could do it, I rea1ly don't.
a So then the route trying to make a
comparison between an underground version of it and a
compJ-ete1y above ground version of it is, in your
opinion, not an apples-to-apples comparison?
A Meaning with the underground, I believe we
can get that done. I don't think we can do the overhead;
is that what you mean by --
O Yeah, just as far as costs, you probably
coul-dnrt make an apples-to-apples comparison and say that
the routes are the same, because the routes have
completely
different
consideration
components tied
that you brought
to some of the safety
out; correct?
different characteristlcs and completely
cost
Thanks.
much. Thank
A Yeah, that's correct.
COMMTSSIONER KJELLANDER: Okay, I'm done.
THE WITNESS: You bet.
COMMISSIONER ANDERSON: Any redirect?
MR. WALKER: No redirect, Mr. Chairman.
COMMISSIONER ANDERSON: Thank you very
you, Mr. Porter.I 25
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CSB REPORT]NG(208) 890-s198
PORTER (ReDi)
Idaho Power Company
THE WITNESS: Thank you.
(The witness l-eft the stand. )
COMMISSIONER ANDERSON: Back at quarter
to. That ' s f our-and-a-hal-f or three-and-a-hal-f .
(Recess. )
COMMISSIONER ANDERSON: We'Il come back to
order. I bel-ieve the Applicant has
MR. WALKER: Yes, Mr.
very l-imited redirect issue with Mr.
a request.
Chairman, I have one
Porter, if f could
have him please take the stand again.
COMMISSIONER ANDERSON: Without objection,
please take the stand.
MR. WALKER: Thank you Mr. Chairman.
VERN PORTER,
produced as a witness at the instance of the Idaho Power
Company, havlng been previously duly sworn to tel1 the
truth, the whol-e truth, and nothing but the truth,
resumed the stand and was further examined and testified
as f o1.l-ows:
REDIRECT EXAMINAT]ON
BY MR. WALKER:
0 Mr. Porter, during much of your discussionI25
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CSB REPORTING(208) 890-s198
PORTER (ReDi)
Idaho Power Company
with Mr. Adams who was the first to cross-examine you,
you referenced the Company's base case as being
underground distribution and is that correct?
A That is not correct. It's overhead
distribution.
MR. WALKER: Thank you. That's all I
have.
COMMISSIONER ANDERSON: Thank you very
much. Thank you again.
(The witness left the stand. )
COMMISSIONER ANDERSON: And there are n'o
further witnesses?
MR. WALKER: No further witnesses from
Idaho Power, Mr. Chairman.
COMMISSIONER ANDERSON :
much. We're going to move on to the
Thank you very
intervenor witnesses
and we're going to use the same protocol, the format that
going to call- Rock Rolling. Mr.
to cal-l- your witness?
we had before, and f'm
Adams, would you like
MR. ADAMS: Chair Anderson, we did not
fil-e any prefiled testimony and don't have a witness to
sponsor.
COMMISSIONER ANDERSON: Thank you, you're
correct.
MR. ADAMS: Thank you.25
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CSB REPORTING
(208 ) 890-s198
CHERP (Di)
CoxCom, LLC
COMMISSIONER ANDERSON: Mr. Richardson.
MR. RICHARDSON: Mr. Chaj-rman, we also
have no witness.
COMMISSIONER ANDERSON: Sierra Cl-ub,
Ms. Nunez.
MS. NUNEZ: We do have a witness, but
we've been requested by Cox to have their witness go
first for travel purposes and we are okay with that 1f
the Commission is.
COMMISSIONER ANDERSON: That's perfectly
f ine. We'11- go to Cox, then.
MR. ARKOOSH: We'd call Guy Cherp, Your
Honor.
GUY CHERP,
produced as a witness
having been first duly
truth, and nothlng but
testified as follows:
at the instance of CoxCom, LLC,
sworn to tel-l- the truth, the whol-e
the truth, was examined and
DIRECT EXAMTNATION
BY MR. ARKOOSH:
O Would you state your name and spe11 your
Iast name, please?I 25
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CSB REPORTING(208) 890-5198
CHERP (Di)
CoxCom, LLC
A Guy Cherp. Last name is spelled
C-h-e-r-p.
O And how are you employed?
A With Cox Communications.
O And what is your position with Cox?
A Vice president and market l-eader.
O Are you the same Guy Cherp that fil-ed
direct testimony on May 5th of this year?
A Iam.
O And did you hear the testimony of Mr.
Ange11 regardi-ng a change that had occurred regarding Cox
Communicatj-ons because of negotiations between Cox and
Idaho Power?
A r did.
O And was he true and correct in that
matter?
A Yes.
a Other than that, are there any changes in
your testimony?
A No.
MR. ARKOOSH: I would move that Mr.
Cherp's testimony be spread upon the
COMMISSIONER ANDERSON :
record.
Seeing no
objection, his
record.
testj-mony wiII be spread upon thet25
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(The following prefiled direct testimony
of Mr. Guy Cherp is spread upon the record. )
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CSB REPORTING
(208 ) 890-s198
CHERP (Di)
CoxCom, LLC
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O. Please state your name.
A. Guy Cherp.
0. Where do you reside?
A. I currently reside in Sun Va11ey, Idaho.
a. What is your educational- background?
A. I have a B.A. in Economics and Environmental-
Conservation f rom the Univers j-ty of Col-orado.
O. What is your work experience in communications?
A. My experj-ence in communicatj-ons is primarily
with Cox. f have worked for Cox Communi-cations, Inc.,
since 2002 in various management and leadership roles.
Prior to that, I worked for Cox Interactive Media, Inc.,
a former operating division of Cox Enterprises, Inc.,
which was the online presence of Cox's l-ocal media
properties, for five years in various management and
leadership roles.
O. Vfhat is Cox Communications (hereinafter "Cox")?
A. Cox Communications is a broadband
communications and entertainment company, providing
advanced digital video, Internet, telephone and home
security and automation services over its own nationwide
IP network. The third largest U.S. cable company, Cox
serves approxlmately six mill-ion residences and
businesses. Cox Business, a component of Cox
Communications, is a facil-ities-based provj-der of voice,
CHERP, DT 1
CoxCom, LLC, d/b/ a/ Cox
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video and data soluti-ons for commercial customers.
O. What is your employment history with Cox?
CHERP, Df - 1a
CoxCom, LLC, d/b/ a/ Cox
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CHERP, DI 2
CoxCom, LLC, d/b/ a/ Cox
A. I have worked for various Cox Enterprises, Inc.
(the parent company of Cox Communication, Inc. ) operating
companies for a1most 30 years.
O. What is your title with Cox?
A. Vice President and Market Leader.
O. What services does Cox provide in the Wood
River Va11ey?
A. Cox provj-des both residential- and business
customers in the four municipal-ities and surrounding
areas in BIaine County with advanced dj-gita1 video,
Internet, telephone and home and busj-ness securi-ty and
automation services. These Cox services provide critical
connectivity for a vari-ety of sectors including
residential, business and government entities, schools,
hospitals and heal-th care providers.
In the Wood River Val1ey, Cox serves more than
10,000
network
subscribers. Our hybrid fiber optic and coax
is the conduit through which we dellver a wide
range of
continue
advanced video and communications services. We
to make the necessary investments to ensure that
the residents and businesses in our communities have an
entertainment and communications infrastructure to meet
their needs today and in the future.
Cox Communj-cations plays an important role in supporting
in the Wood River Va11ey. Herelocal economic developmento25
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CHE RP,DI
/b/ a/
2a
Cox
are some specif ic exampl-es:
' Co* serves four municlpalities and surrounding
areas in Blaine County with entertainment and
telecommunications services.
' Cox employs 22 f ull-time res j-dents.
' Co" pays nearly 92 million in Idaho payroll
taxes and employee wages annualIy.
a 25
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CHERP, DI 3
CoxCom, LLC, d/b/a/ Cox
a
Cox pays more than $280,000 in municj-pa]
franchise fees annually in Idaho.
Cox pays nearly $1 million to Wood River Val1ey
area contractors and vendors on an annual
basis.
Over the past five years, Cox has invested more
than $18 million in the community, including
new office facilities, a new Master
Tefecommunications Center and network
infrastructure.
Cox provides nearly the entire Wood River area
with state-of-the-art,
our fiber optic
broadband technofogy
using
Please
and coax network.
n describe the Cox's physical facilities
in the Wood River Va11ey.
A. Cox maintains a retalI store, warehouse and
office facility at 340 Lewis Street in Ketchum, Idaho.
In addition, Cox's newly-renovated Master
Tel-ecommunicatj-ons Center (MTC) j-s located at 811 Warm
Springs Road in Ketchum. The MTC location serves as both
our connection receiving point and our central
distribution point to the entire Wood River Va11ey. The
fiber link to our MTC l-ocation is critical to our ability
to provide services in the Wood River Community.
O. What are your duties and responsibil-ities witho25
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CHERP, Df - 3a
CoxCom, LLC, d/b/a/ Cox
regard to
A.
the Cox system in the Wood River Valley?
I oversee all aspects of Cox Communications I
operations in the Wood River Valley.
O. Please describe the interrelationship between
the services provided by Cox in the Wood River Valley and
the rel-iabil-ity of electrical supply.
o 25
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CHERP, Dr - 4
CoxCom, LLC, d/b/a/ Cox
A. Electrical power reliability is crltically
important
f acil-ities
E911-compliant
support daily
customers; and
of us.
Rj-ver VaIIey?
A. Cox
agreement with
to our operation. We count on it to power our
us to provide
connections that
our commercial-
and our network, enabling
lifel-ine connections ;
busj-ness operations for
critlcal- connections to the worl-d for all-
O. By what authority does Cox operate in the Wood
Valley
Idaho
that are at
our rights
and federal-
using their
facilities.
attachment
compensate
equipment
o.
services to power
Additionally, as
our entire network and
has held a state-issued video franchise
a certificate to operate in the Wood River
since July 2011. Further, we have a contract with
Power Company to attach facil-ities to their poles
issue in this matter. This contract refines
to attach to these poles as provided in state
l-aw.
O. Pl-ease describe the business relationship
between Cox and Idaho Power Company.
A. Cox is a significant Idaho Power customer,
indicated, Cox has a pole
agreement with Idaho Power, whereby we
Idaho Power for the right to attach our
to their poles.
Pl-ease descrj-be the physical- rel-ationshipO25
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CHERP, DI 4a
CoxCom, LLC, d/b/a/ Cox
between the Cox facilities and the Idaho Power facil-ities
in the Wood River VaIIey.
A. Cox's equipment is attached to Idaho Powerrs
poles throughout the service area. Our transport and
distribution networks attach to the route of the poles
under consideratj-on for fdaho Power's redundancy
transmission l-ine route from Hailey to Ketchum/Sun
Va11ey.
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CHERP, DI 5
CoxCom, LLC, d/b/ a/ Cox
O. Have you read the Application in this matter?
A. Yes.
A. What effect do you anticipate denia1 of the
Application will have upon Cox and its customers?
A. The status quo will be maintained with no
impact to Cox. Cox will continue to be a tenant on the
existing Idaho Power's
our customers will not
have upon Cox and its
order granting
customers ?
A. The impact to Cox and its customers will depend
on the form of the final- order. If it authori-zes Idaho
Power to replace its current distribution poles in order
to accommodate transmission facilities, but the pole
height is restricted to such a degree that there is no
room for telecommunications cabling, then Cox wi-11- be
requlred to either seek permission to install its own
separate poles or bury our current aerial cabling.
Either comes at tremendous added cost and wou]d have the
effect of redirecting capital doll-ars otherwise vj-tal to
continuous and ongoing upgrades to our network. This
particular option woul-d have the effect of
O. What effect
the Application will
in a discriminatory manner, and under
request the intervenors favoring this
to reimburse Cox for the difference in
Highway 75 pole run
be interrupted.
do you anticipate an
stat e
and service to
treating Cox
law Cox would
option be ordered
cost between25
50s
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CHERP, DI 5A
CoxCom, LLC, d/b/a/ Cox
aerj-af and underground placement. Maintenance and
rel-iability are very realistic concerns if Cox's
communication facil-ities are forced underground. These
attributes become more difficult
Access for maintenance becomes a
underground facil-ities. Because
to sustain underground.
special concern for
we must
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CHERP, DI 6
CoxCom, LLC, d/b/a/ Cox
remain E911 compliant, such a massive al-teration to our
system and j-ts consequences, both known and unknown,
incite some apprehension.
In the alternative, if the final- order authorizes
poles that al-so can accommodate tel-ecommunications
facilities then it would simply be a matter of Cox
coordinating the transfer of our existing aerial l-ines to
the new poles upon concl-usion of instal-lation. Under
formul-a adopted by the FCC and recognized by the Idaho
Public Utj-lities Commission, Cox would continue to
compensate Idaho Power for the right to occupy these
budgeted and ongoing standardpo1es, which
operational
o. rf
l_s a
expense.
the Idaho Public Utilities Commission
("PUC") grants the Application in a modified form by
ordering Idaho Power's redundant transmissj-on facility
between the Hailey and Ketchum substations be buried
underground, what effect do you anticipate that order
will have on Cox and its customers?
A. In this instance Cox wou1d be required to
either seek permission to install our own poles or
convert our current aerial- cabllng to underground.
Ej-ther option would be very expensive and woul-d divert
scarce capi-tal dol-l-ars away from ongoj-ng network upgrades
and ultj-mately impacting end customer experience andI25
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CHER
CoxCom, LLC,
P, DI
d/b /
a-- od.
a/ Cox
value.
O. What is Cox's preference in
we are reliant
this matter?
-H.As indicated,
of el-ectricity
upon the refiable
provision
must defer
that Ievel
this will-
to service our customers and
to Idaho Power and the Commission to achieve
of performance. If the Commission determines
be accomplished with the current system, we are
our current arrangement with Idaho Power.
the Commission grants the certificate, we
it assure the u]-timate
content with
Tf, however,
request that
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CHERP, DI 7
CoxCom, LLC, d/b/ a/ Cox
physical facil-itles
of our equipment to
O. Does this
A. Yes.
authorized can accommodate attachment
the new po1es.
conclude your direct testimony?
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CSB REPORTING(208) 890-s1_98
CHERP
CoxCom, LLC
(The fol-lowing proceedings were had in
open hearing. )
MR. ARKOOSH: He's avail-able for
cross-examination, Mr. Chairman.
COMMISSIONER ANDERSON: Thank you. The
Applicant?
MR. WALKER: No questions from Idaho
Power, Mr. Chairman.
COMMISSIONER ANDERSON: Thank you. We'll-
look through our l-1st of i-ntervenors. Mr. Adams
MR. ADAMS: We have no questj-ons, Mr
Chair.
COMMISSIONER ANDERSON: Mr. Richardson.
MR. RICHARDSON: No questions,
Mr. Chairman.
COMMISSIONER ANDERSON: Ms. Nunez
MS. NUNEZ: No questions. Thank you.
Ketchum.COMMISSIONER ANDERSON: City of
MR. JOHNSON: No questions.
COMMISSIONER ANDERSON: No questions.
Staff.
MS. HUANG: No questions.
COMMISSIONER ANDERSON: No questions.
Commissioners? And no redirect. Wel-1, thank you.
THE WITNESS: Thank you.I 25
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CSB REPORTING(208) 890-5198
HECKLER (Di)
Idaho Sierra Cl-ub
(The witness l-eft the stand.)
COMMISSIONER ANDERSON: If you'11 speak in
your microphone.
MR. ARKOOSH: Mr. Adams took my
microphone.
attendance
May Mr. Cherp be excused from further
after today if this goes further?
COMMISSIONER ANDERSON: Without objection,
yes, he may.
MR. ARKOOSH: Thank you.
COMMISSIONER ANDERSON: Sierra Club, Ms.
Nunez.
MS. NUNEZ: Sierra Cl-ub woul-d l-ike to cal-l-
its first and only witness Michael- Heckl-er.
MICHAEL HECKLER,
produced as a witness at the instance of the Idaho Sierra
C1ub, having been first duly sworn to tel-l- the truth, the
whol-e truth, and nothing but the truth, was examined and
testified as follows:
DIRECT EXAMINATION
BY MS. NUNEZ:
O Will you please state your name and your
record?position wlth the Sierra Cl-ub for theI25
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CSB REPORTING
(208 ) 890-s198
HECKLER (Di)
Idaho Sierra Club
A My name is Michael- Heckler, H-e-c-k-1-e-r.
I'm chair of the energy committee.
a Are you the same Mike Heckler who filed
direct testimony on May 5th and rebuttal testj-mony on
June 23rd as well as Exhibits No. 301 through 323?
A
o
Yes,
Mr.
Iam
Heckler,
that youor
prefiled testimony?
A I do.
mistake and the other
do you have any corrections
would like to make to your
I have two. One of them is my
one is my understanding of what
on page 10 of my
error, so there's a
in the
clari ficat ions
Dave said
testi-mony,
l-i-ne would
thls mornlng.
on l-ine 3, it
On page 1 of my direct
says right now that the proposed
cross the existing WDRI-KCHM line. I propose
changing that from "would cross" to "comes close to
crossing, " but more substantively,
testimony, I made an Excel summing
table at the top of that page and heading it says
the fourth line15.3 hours, you see that at the bottom of
in the title, that should be l1 hours.
up the 1.7-hour maintenance outage in
Excel summing area broadly
I fail-ed to pick
1995. I didn't
enough, and then
refers to those 15.3
those changes,
spread the
again down
hours and
there's no
on l-ine 21, it once
it should be 7J, but
again
with
other clarlfications I would make.25
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CSB REPORTING
(208 ) 890-s198
HECKLER (Di)
Idaho Sierra Club
O Thank
cl-arifications , if I
woul-d you provide the
A Yes, I
you.
asked
same
With these corrections and
you these questions again,
answers ?
wouId.
MS. NUNEZ: f move to spread Mr. Hecklerfs
direct and rebuttal- testimony with these corrections and
clarifications across the record.
COMMISSIONER ANDERSON: Seeing no
objection, the testimony with clarifications and
corrections is spread on the record.
(The following prefiled direct and
rebuttal testimony of Mr. Michael Heckler is spread upon
the record. )
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HECKLER, DI 1
]DAHO STERRA CLUB
O. What is the
in this proceeding?
A. Wh1le this
issues re]ated to land use
Idaho Si-erra Cl-ub' s interest
docket raises substantial-
and scenic va1ues, the
interest of the ldaho Sierra Cl-ub ("Sierra Club")
primarily focuses on the technical and financial
of the Idaho Power Company ("Company") proposal.
to intervene and testify because the Company has
provided an adequate review of relevant costs and
aspects
We chose
not
technical alternatlves to their proposed redundant
transmission l-lne, and as such the proposal is not
consistent with what the Sierra Cl-ub sees as the public
i-nterest.
We believe that a more robust consideration of
alternatives is in the public interest and that a
combination of a rebuil-t l-1ne along the existing
right-of-way with some grid edge resource al-ternatives
can provide excellent resiliency at a lower cost than the
proposed redundant transmission solution. Such resiliency
in the North Wood River Va1ley ("NWRV") may help
facilitate the City of Ketchumr s ability to real-ize their
clean energy objectives, which are in alignment with
Sj-erra Cl-ub's efforts to promote the decarbonization of
the e]ectric sector.
O. P1ease summarj-ze Sj-erra Cl-ub's concernsI25
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HECKLER, DI 1A
IDAHO SIERRA CLUB
with the proposal.
TheA Company seeks an order to "construct
i-mprovements to its el-ectric transmission system to
secure
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adequate servj-ce to its customers."l We agree some
improvements to the NInIRV transmission system are 1ikeIy
warranted, but the Company has fail-ed to show that
building an additional transmission line is the most
cost-effective solution availabl-e.
The Company has been working, at least
intermittently, on buil-ding an additional transmission
l-ine from Hailey to Ketchum for 44 years. Technology has
changed radical-ly during the l-ast four decades, yet the
Company has contj-nued to push ahead with their same
preferred solution from 7973. We bel-ieve there are now
alternatives that could provide a higher l-evel of
benefits for al-1 customers of the Company while ensuring
adequate and reliabl-e service in the NWRV, but those have
not yet been properly analyzed.
While the Sierra Club is willing to concede that the
existing line 1s "aging and now requires complete
reconstruction"2, we do not think the information in this
docket is adequate to support the Company's proposal to
build an additional transmission l-ine. Further, we do not
believe that building a redundant transmission 1ine, with
a 70 to 8O-year useful l-ife, is a cost-effective
technical solution or a sol-uti-on that addresses more than
a narrow portion of the NWRV delivery system.
HECKLER, D] 2
IDAHO SIERRA CLUB
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HECKLER, DI 2A
IDAHO SIERRA CLUB
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O. Why do you think the proposal does not
include adequate informatj-on?
A. The proposal does not contain enough
relevant informati-on about alternative sol-utions to
rel-iabil-ity problems in this rel-atively remote and
mountainous portion of the Company's service territory.
As such, it precludes an informed decision on how to best
ensure reliable and adequate service to the NWRV. Sierra
Club acknowl-edges that on technical- questions l-ike
re1iabi11ty, the Commission often defers to the Company,
but we are operating in a time of rapid technological
change in the el-ectri-c utility industry. A thorough
analysis of al-ternatives is more important now than it
was even a decade d9o, and because the proposal- does not
include an adequat.ely completed analysi-s, such deference
is not appropriate at this time.
0. Pl-ease describe your rol-e with the Sierra
Club and a summary of your relevant experience with the
issues in this proceeding.
A. I am the Chair of the Idaho Sierra Club's
Energy Committee. Prior to my retirement tn 20L2, I had
multiple professional- roles. V[hiIe I rea]-ize that the
decisions made by a public body such as this Commission
must bal-ance far more than the primarily commercial
va1ues I addressed in the private sector, during my
HECKLER, DI 3
IDAHO S]ERRA CLUB
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career I helped resolve many matters with cost and
technical complexity similar to the issues raised in this
docket.
HECKLER, DI 3A
IDAHO S]ERRA CLUB
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HECKLER, DI 4
IDAHO SIERRA CLUB
At SeaFirst Bank, I administered budgeting and
profit plan performance measurement for the bank. At
Boeing, among other things, I managed budgeting,
instal-lation and operation of computing hardware in a
large-scale sclentific data center. I have managed
multiple procurements and projects with contract val-ues
measured in tens and hundreds of mil-l,ions of dol-lars.
My academic tralning includes bachelors, masters and
doctoral- level- degrees in accounting, finance and 1aw,
respectively.
For approximatel-y a decade beginning in 2002, I
worked as a wind farm developer. I have been an active
participant in every Idaho Power Company Integrated
Resource Planning process from 2002 through 201,7 and on
multiple instances have provlded comments/testimony
before this Commission.
I appreciate the opportunity to submit testimony in
this docket.
RELIABTLITY
o.
adequate and
what concerns
Given the Company's duty to provide
re1iable service to customers in the NWRV,
does Sierra CIub have with how matters
re1ated to reliability have been addressed in this
docket ?
Sierra Club accepts and completelyo25
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supports the need to provide rel-iabl-e electric service to
customers in the NWRV. We are concerned that errors and
misrepresentatj-ons have occurred in the terminology the
Company has employed and in the
HECKLER, DI 4A
IDAHO SIERRA CLUB
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HECKLER, DI 5
IDAHO SIERRA CLUB
scope of review they have conducted on matters related to
continuing to provide relj-able service. These errors and
misrepresentations take three forms:
1. A confusion of the concepts rel-ated to
rel-iabIe, redundant and proximate.
2. An insufficient review of the
"rel-j-abi1ity" of the existing WDRI-KCHM line.
3. A resultant proposal to over-build a
portion of the NWRV delivery system.
O. Can you explain your perspective on the
relationship between "reliability" and "redundancy" as
presented in the Application?
A. Mr. Angell characterizes the proposed
redundant transmissj-on line as a need, adding that it
would also a11ow for load growth and facilitate
rebuilding of the existing line.3 Sierra Club is
concerned with how the Company conflates "reliabiIity"
and "redundancy" and "redundancy" with "physical
proximity".
Constructing redundant transmj-ssion lines is but one
method for enhancing reliable service, but redundancy i-s
not the need itself. Rel-iable service is the need.
Transmission is one way to
reliability, and redundant
improve transmission
transmission is one way to
provide transmj-ssj-on. The Company's characterizationa25
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3 See Ange11 al 2, 2L-23.
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HECKLER, DI 5A
IDAHO SIERRA CLUB
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HECKLER, DI 6
]DAHO SIERRA CLUB
of a redundant transmission l-ine into the NWRV as a need
mischaracterizes one potential solution for providing
future reliab]e service with the need itself.
O. Can you explai-n why it is probJ-ematic to
mischaracterize redundancy as a need instead of one
potential- solution?
A. Mischaracterizing redundancy as a need has
shj-fted the focus of analysis onto the detail-s of
designing and locating the redundant line instead of on a
thorough and necessary review of the measure of rel-iable
service needed in the NWRV. This shift has precluded an
adequate analysis of alternative methods for meeting the
reliability standard.
O. Can you explain your concerns with how the
Company conflated the concepts of physical proximity and
redundancy?
A.When Mr. Ange11 explained why the Company
had not proposed accessing the KCHM substation over the
same route the existing line uses running from the EKHN
substation, he faul-ted that route as failing the "need"
for redundancy. He argued that where the proposed new
l-ine wou1d run near the existing l-ine thej-r proximity
would raise
i-ncapaci-tate
that follow
the risk that a single event coul-d
both lines.a We have two major concerns
from this fine of argument.t 25
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HECKLER, DI 6a
IDAHO SIERRA CLUB
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First, the Company's proposed route is not free from
the stated problem of havj-ng two l-ines being in cl-ose
proximity of each other. The proposed line comes close to
crossing the existing WDRI-KCHM l-ine within a quarter
mil-e of where both l-ines l-eave their common source at the
WDRI substation. Moreover, and there are never more than
a few hundred yards separating the two l-ines for the
first few miles of their routes north of WDRI (until they
are some ways
Second,
substation is
proposed new
substation as
north of Ohio Gulch Road) . s
and perhaps more fundamentally, the WDRI
point of failure. The
would originate from the same
the existing l-ine. Because both lines are
dependent upon the operational integrity of that single
substation, the proposed redundant line wil-l not provide
an independent source of energy as the Company purports.6
O. Pl-ease el-aborate on the issue of the WDRI
substation being a single point of fail-ure.
A. The Company's proposed redundant line
coul-d not provide any power to NWRV if an outage event
affected the WDRI substation. The 70O-minute outage on
December 24, 2009 was due to
5 Angefl, Exhibit 4.
6 Direct Testimony of Michael- J. Youngblood, Exhibit L aL 2
stil-l- a single
redundant line
HECKLER, DI 1
]DAHO S]ERRA CLUB
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Ioss of electric supply to the WDRI substation.T That
was one of two line outages the Company lj-sted
WDRI-KCHM l-ine that were not caused by fail-ures
portj-on of the existing line and would not have
mitigated by
was getting
outage that occurred on June 4, 2074 was caused by broken
cross arms and affected 20r228 customers.s Given that
there are approximately 9,100 customers in the NWRVe, it
follows that this outage must have impacted the system at
the WDRI substation or south.
redundant lines from WDRI because
to V[DR] substation. The second was
for the
on any
been
no power
4 5-minute
a. rf
redundant line as
for reliability,
we re-characterize the proposed
so]ution to the need
can you
redundant
potential
to the need itself,
please explain your concerns with selecting the
just one
as opposed
l-ine as the solution?
A. Yes, but first I
second analysis deficiency - an
the rel-iability of the existing
new, cl-earer context.
O. Please el-aborate.
woul-d like to put the
insufficient review of
WDRI-KCHM line into a
7 Idaho Power Company's Response to Tidwell-rs Request for
Production No. 31, Exhibit No. 301.B Idaho Power Companyrs Response to Staffrs Request for Producti-on
No. I , Exhibj-t 302 .
9 Angeff at 3.
HECKLER, DI 8
IDAHO S]ERRA CLUB
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HECKLER, DI 9
IDAHO SIERRA CLUB
A. The history of the existing l-ine's
reliability suggests that a rebuil-t l-ine could also
provide excellent reliability.
Pri-or to the Company requesting that its CPCN from
1913 be cancelled, they retained Engineering Data
Management, Inc. ("EDM") to review the structural-
condition and el-ectrical- reliability of the WDRI-KCHM
l-ine and analyze its condition.l0 BDM's 1993 Electrical
Reliability Study analyzed the total of three minutes of
outages from 1980 to 1993 and concluded:
"The outage records speak for themselves. Two
outages in the past fourteen years for a total-duration of three minutes include one weather
related outage, attri-buted to heavy snow and one
switching outage. The l-ow incidence of lightningthis area combined with the l-ine's proximity to
mountains and relatively good condition of theentire power l-ine give the Wood River to Ketchum
138kV Transmission Line an operating record thatpractically unsurpassable. "ll
in
the
l_s
o.
graphically?
A.
Can you show the sustained outage history
I created the following figure showing
outage history with data provided by the Company:
10 Idaho Power Company's Response to Tidwell-'s Request for
Production No. 18, Attachment 2 (the Electrical Data Management,
fnc.'s Electrical Refiability Study)r pages 1-3 as Exhibit 303.11 El-ectricaf Data Management, Inc.'s El-ectrical Re.l-iability Study
at 3, Exhibit 303.I 25
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HECKLER, DI 1O
IDAHO SIERRA CLUB
The WDRI-KCHM tine has been in use for 55 years arrd has expcrienced four
unplannercl sustainccl outages - for a total duratiorr of 3.3 hours ovcr 55
ye;rrs. Sincr, L995 the' linc lras been taken clown for an additional * l4
hours for planrrecl (nraintcrrance) out.:ges
7.75
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1.7 1.8
1.0
I 0.1 0.2,
{!
The Company was not able to document any outages
before L995, although EDM moved that record back to 1980.
Based on the data provided, between 1980 and 2016 the
line experienced only 3.3 hours of sustained unplanned
outages.l2 3.3 hours in 35 years. If we divide 3.3 by the
total number of hours in those 35 years it implies that
over the three and half decades from the first Reagan
election to the present, the lj-ne has not experienced an
outage 99.9992 of the time.
During that 35-year period, there were another t7
hours of planned outages for maintenance. The plannedo25
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outages were done
1'2 Idaho Power Company's Response to Tidwefl's Request for
Production No. 13, Attachment 1, Exhibit 304.
HECKLER, Dr 10a
IDAHO S]ERRA CLUB
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during off-season (May, September, or October) 13 and at
times when total KCHM and EKHN load were l-ess than
15MWs.14
The Company's records show that outages in December
or January have totaled only 10 minuteslS, which is far
less than the 24-hour time period the Company used as a
requirement in its analysis of alternatives. l6
Given this history of rel-atively rare, short-
duration unplanned outages that show no seasonal pattern,
combined with an operating history the Companyrs
contractor characterized as "practically unsurpassabfe"lT,
there is no reason to bel-ieve that a newly rebuil-t
transmission line cannot provide the same exceptional
reliability, if not better.
Exceptional rel-iability is even more 1ikely given
the Company's plans to reconstruct the existing line with
steel poles that will- have a better structural capacity
and be able to
13 sxhibit 304.
14 Idaho Power Company's Response to Idaho Sierra Cl-ub's Eirst
Request for Production No. 8, Exhibit 305.
1s exhibit 304.
16 Angell at l-4.
17 Spyts Electric Reliability Study at 2, Exhibit 303.t 25
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HECKLER, DI 12
IDAHO SIERRA CLUB
withstand some threats better than the wood poJ-es
currently in use.18
O. Moving back to your concern with the
redundant l-ine option, you mentioned that the redundant
line would l-ead to "over-bu1lding" a portion of the NWRV
el-ectric delivery system. What is the nature of your
concern?
A. Let me respond first to the issues rel-ated
to analyzi-ng just a "portion" of the NWRV delivery system
before covering concerns rel-ated to "over-bui1ding".
As I described above, al-l- energy that would be
available for transmission across the proposed redundant
l-ine comes via the WDRf substation.SimilarIy,
the NWRVcustomers in the affected portlon of get their
service via distribution lines running from the KCHM or
EKHN substations. Upgrading the linkages between WDRI and
KCHM/EKHN does not protect customers from outages arising
on either end of those transmission l-inks (those ends
being at the WDRI substation or on a distribution line).
Regarding over-building a portion of the system, it
was described above that the existing WDRI-KCHM l-ine has
proved 99.999% reliable against unplanned outages. In the
Company's Response to Tidwel-l-'s Request for Production
No. 51, Mr. Ange11 stated that should the proposed
redundant line be built the
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18 See Idaho Power Company's Response to Idaho Sierra CIub's Request
for Production No. 2, Exhibit 306.
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IDAHO SIERRA CLUB
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probability of concurrent outages on two 13BkV lines
between the V0DRI and KCHM substations would rise to one
outage in 31000 years.19 It is not clear that there is
much of a practical, signlficant difference between
99.9992 rel-iable and one outage in 3,000 years, or that
this supposed reliability "improvement" can justify the
costs proposed by the Application.
ApEQUACY
O. Please summarize your understanding of the
Company's argument that a redundant line is needed to
accommodate future l-oad growth.
A. As I read the Company's applj_cation and
supporting materials, I can summarize the argument as
follows: One of the justifications for building a
redundant l-ine is based on assumptions about future load
growth in the NWRV. Specifically, in both the 2007 and
201,1, Wood River Valley el-ectric p1ans, Ioad growth is
projected to grow to 80MW served from the Ketchum
substation and 4OMWs served from the Elkhorn substati_on2o.
Since the existing line has a capacity of 120MWs, it is
said that such future load growth will require some
safety margin in transmission capacity and the redundant
line is partially justified as a source of additional
capacity.
HECKLER, DI 13
IDAHO SIERRA CLUB
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20 An
No . 51,
19 r Power Company's Response to Tidwell's Request for Production
Exhibit 307.
f Exhlbit 2, Appendix C at 7-8
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IDAHO SIERRA CLUB
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Do you agree with that assessment?
No.
Please explain why not.
A. Currently, peak loads rise to about 50% of
the existing line's 12OMW capacity and average l-oads are,
of course, Iower. History doesn't support the Company's
projections of future foad growth and calls into question
the methodology used to develop those projectj-ons.
Both the 2001 and 2011 versions of the Wood River
ValIey electric plan forecast that loads will more than
triple over the lifespan of the proposed redundant
transmission line. One of the methods used to forecast
that growth was based on population growth projections
provided by John Church, Presi-dent of Idaho Economics.
Looking at the 2006 population of Blaine County
north of Timmerman Hill up to SNRA headquarters (21,600
people using a winter peak of 99.5MWs), Church and the
Company projected this population to grow at a compound
annual- rate of 1.8% per year. That growth rate implied
that by 2080, the population of the area woul-d be '76,161.
Church then assumed that each of the '76,167 persons wou1d
demand an average of 4.2kW. Multiplying 16,167 people by
4.2kW per person yields "about 320MW for total Wood River
Va11ey area buildout l-oad"21. The Company subdivided that
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IDAHO SIERRA CLUB
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IDAHO SIERRA CLUB
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projected 320MWs by
substations further
substation, allocating 20OMWs to
south and forecasting 8OMWs for
substation l-oads.22Ketchum and 4OMWs for Elkhorn
O. What is the flaw you see in this analysis?
A. Peak winter l-oad in 1994-1995 was 55.5
MW.23 This past winter it was 55.8MW. The foJ-lowing graph
displays pe
It clearly
compounding
plans:
ak l-oads on the WDRI-KCHM
shows that in the last 10
line this century.24
years, growth is not
2001 and 2011at the rate stated in the
22 See Angell Exhibit 2, Appendix C at 7-8
23 Staffrs Request for Production to Idaho Power Company No. 76,
Exhibit 308.
24 The data in the graph were provided in Table 7.1 of Idaho Power
Company's Response to Tidwel-l-'s Request for Production No. 7, Exhibit
309, and Idaho Power Company's Response to Idaho Sierra Club's
Request for Producti-on No. 18, Exhlbit 310.
HECKLER, Dr 15
IDAHO SIERRA CLUB
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HECKLER, DT 16
IDAHO SIERRA CLUB
HWRU PEAH [WtFtTEnl LOAn
633'
E E 3 E 5 E E B g = =: I = g g
=i = i t *'6 tE r t E +* n A };t, +gqqzEqft,t3{f(fd'-;?FE E E E E H E H E H E S E EH frE
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First, while load growth may have looked to be on an
upward slope in 2006, Ioad has been largely flat in the
NWRV since the 2008 recession (as has been the case
throughout most of the country) . The Companyr s 2007 /20L!
analyses do not acknowledge that reality.
Second, just as more efficient electric-powered
products (Iights, motors, computers, etc. ) have upset
traditional trends in electricity l-oad growth, policy
decisions by staLes and localities limit the likelihood
of rapid load growth in the future. For example, the City
of Ketchum's 20L5 Energy/t 25
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HECKLER, DI 71
]DAHO SIERRA CLUB
Conservation Goal-s incl-ude a city-wide target of 50% per
in energy use by 2030.2scapita
As Ketchum Residents represent the majority of the
electric load in the NWRV area26, their actions in
reducing energy consumption per capita are rel-evant to
any projected future load growth analysis. Combining
reduced consumption policies with high l-ocal- property
prices that constrain extensive new development in the
area, the Company's hiqh annual compound population
growth estimates are unrealistic and make the Company's
NWRV l-oad projections suspect.
In sum, the 12OMW capacity of the existing WDRf-KCHM
Iine is likely to be adequate to serve local load into
the f oreseeabl-e future.
O. Even if there doesn't appear to be
substantial- NWRV l-oad growth in the near future, what
about the Company's projections out to 2080?
A. Projecting load growth over the next 60
years is speculative in and of itsel-f, and is an
j-nappropriate basis for justifying building an expensive,
long-Iived asset using todayrs
25 See City of Ketchum Resolution No. 75-072, Regarding Establishment
of Energy Conservation Goal-s for the City of Ketchum (March 10,
2Ol5), Exhibit 311.
26 Idaho Power Company's Response to Idaho Sierra Cfub's Request for
Production No. 13, Exhibit 312.
reductions
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conventional transmission technology. The rapid
technological development taking place in the utility
sector, especially rapid advances in options for
improving reliability with "grid edge" resources2T, makes
it like1y that even if the NWRV experiences substantiat
Ioad growth l-ater in this century, other al-ternative
solutions will- be avai]able at that time to more cost
effectively address those reguirements.
A. Putting aside the conversation about
distributed resources for
near-term afternati-ves for
system without building a
A. Perhaps the
constructed with a larger
its capacity.
now, do you see any other
increasing capacity on the
redundant l-ine?
rebuilt existing line could be
conductor that would increase
A}IATYSIS DEFICIENCIES
Pl-ease describe your concerns with theo.
Company's
A.
analysis
My
of alternative generation resources.
is that the analysisgeneral concern
was not conducted objectively. During my career, I
witnessed multiple
27 See Elaine Wi.l-Liams, "Knowledge Gained As Power Conserved", The
Lewiston Tribune (Apri1 9, 2077), avaiJabLe at
http: / /www. spokesman. com/stories / 201'7 / apr / 09 /knowledge-gained-
as-poryer:tenlerveq/, Exhibit 313
HECKLER, DI 1B
IDAHO SIERRA CLUB
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instances where a technical group would attempt to
justify sel-ection of a particular computer hardware or
software supplier by constructing their analysis in a way
that only that one supplj-er could meet. This docket
strikes me as another instance of justification
substituting for analysis.
Additional- information, beyond what the Company has
provided to date, is necessary to concl-ude that a
redundant lj-ne is needed or that redundancy is the
l-owest-cost or even a cost-effective method for supplying
reliability
alternative
alternatives
provi-des the
need to be
fn
requirements. To determine that an
lowest-cost sol-utj-on, multiple
properly eval-uated without a
mind. The analysis submittedpredetermined outcome
with the Application
conclusion.
O. Pl-ease
is insufficient to support either
elaborate on the insufficiencies in
the a]ternative
A.
techniques
including:
analysis.
The Company used multiple inappropriate
in their purported alternatives analysis
Using their redundant line proposal as basel-1ne
against which al-ternatives were compared rather
than comparing alternatj-ves against a need for
reliabl-e service;
HECKLER, DI 19
IDAHO SIERRA CLUB
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Excluding relevant costs from their anal-ysis;
Over estimating costs for some al-ternativesi
Eailing to acknowledge potential- synergies
between alternatives; and
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IDAHO SIERRA CLUB
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IDAHO S]ERRA CLUB
' Failing to evaluate benefits that some
alternatives coul-d provide, focusi-ng soIely on
costs rather than the appropriate cost/benefit
standard for measurement.
f wil-J, address the folJ-owing flaws in turn: (i) wrong
basel-ine; (ii) misslng cost data; (iii) wrong cost
estimates; (iv) ignored combinations; and (v) ignored
benefits.
WRONG BASELINE.The hypothetica1 outage conditi-ons
that the Company used to test alternative resources
(hereafter "distributed energy resources" or "DERs")
against were (i) 24 hour outage (ii) at the peak of
winter season (iii) with a heating l-oad driven by
temperatures staying at -2tE for the entire period and
(iv) an assumption of a requirement to serve al-l- load
rather than just critical- load during outage periods.
These timing, Ioad and duration conditions have
never appeared in reported outage history, and assessment
under these conditions leads to misl-eading concl-usions
about the DERs' abil-ity to serve temporary system
outages.
Since the WDRI-KCHM l-1ne was buil-t back during the
Kennedy presj-dency, the longest documented unplanned
outaqe due to a fai1ure on the line between WDRI and KCHM
was 2 hours and 6 minutes.28 The longest outage during25
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the December January peak
28 Idaho Power Company's Attachment 1 submitted in Response to
Tidwel-f 's Request for Producti-on No. 13, Exhibit 304
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IDAHO SIERRA CLUB
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HECKLER, DI 27
IDAHO SIERRA CLUB
tourist season
outages lasted
was 10 minutes.29 Pl-anned mai-ntenance
up to 8 hours, but those outages were
scheduled
October)
conducted
Iam
in the shoulder season (May,
15MW
September, or
when l-oad was l-ess than and were largely
in the middle of the night.:o
concerned with the adequacy of the results of
We woul-d have betterthe assessment of the DERs.
information to analyze if the assessment was conducted
usj-ng a baselj-ne that more accurately reflected actual
outage history, in duration, l-oad, and seasonal- timing.
MISSING COST DATA.The Company states that the
existing line
provide cost
analyzing the
al-ternatives.
will- need to be re-built but did not
estimates for those activities when
cost of the redundant line and its
Each al-ternative generatj-on source was
29 The December 24, 2009 outage was caused south of WDRf substation
and still- would have had the same effect on the NWRV regardl-ess of
how many transmission l-lnes were install-ed between WDRI and KCHM
substations.
30 As noted above, the need for several of the maintenance outages
(i.e. for wood decay and woodpecker damage) could be mitigated by
rebuilding the existlng line with steel- structures, whi-ch should afso
reduce the potential threat associated with fire, avalanche or
micro-burst winds.t 25
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HECKLER, DI 22
IDAHO SIERRA CLUB
compared to
the cost of
to rebuild
j ust
the
the cost of the redundant l-ine, but not
entire project, which
Iine. Becausethe existing
temporary
used for
includes the cost
the rebuild cost
data is missing, the study does not enable a true
analysis of aII the alternatives and eliminates some
options from being considered.
For example, one basic alternatives analysis coul-d
have compared costs of (1) rebuilding the existi-ng line
and adding some back-up generation for low probability
outages with (2) building the proposed redundant line and
rebuilding the existing line. Such basic cost analysi-s
coul-d fook like:31
The alternative that involves usi-ng "shoo-fly"
line saves more than $25 million that could be
Proposed redundant line Bebuj-l-d existingline without addingf
redundant line
Cost of
redundane line
$30 million Not applicabl-e
Cost to rebuildexisting line
using redundantline'during
outag:es
$6.2 million Not applicable
cost to rebuildexisting lineincluding costof temporary
"shoo-fIy" Iine
Not applicable 99.4 million
Totals 935.2 raillion 99.4 nillion
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31 Data from ldaho Power Company's Response to Idaho Sierra CIub's
First Request for Production No. \, Exhibit 314.
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IDAHO SIERRA CLUB
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IDAHO SIERRA CLUB
resources to cover for limited risk outages and provide
benefits general to the Company customer base at other
times.
Given that total load during maj-ntenance periods was
l-ess than 15MWs, there shoul-d be enough out of the $25
mil-l-ion savings to pay for maintenance backup.32
WRONG COSTS. The cost estimates for some key
al-ternatives are al-so inappropriate and overstated. The
Company compares batteries that are priced at $800 /kWh.,
but Tesla j-s currently offering them for around $250.33
The gas turbines analyzed are sized greater than 5OMWs,
for which the Company says there is not enough fue1. The
Company could have analyzed the smaller and lower cost
reciprocating engine unj-ts that are analyzed in their
Integrated Resource Plan (e.9. Wartsila).34
32 Idaho Power Company's Response to Idaho Sierra Club's Eirst
Request for Production No. 8, Exhj-bit 305.
33 TesIa prices for batteries without instal-l-ation. With
instalfation, the cost wou1d be about $450/kw and declining.
34 Jan 12, 2017 Supp1y Side Resource Operating Inputs shows
Reciprocating Gas Engine aL $775/kw Plant Capital Cost (EPC and other
Owner's Costs). At the April 13 IRPAC meeting, Philip DeVof said that
Wartsifa has been in to visit recently and suggested that some of
their product lj-ne could be priced even l-ower.t 25
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HECKLER, DI 24
IDAHO SIERRA CLUB
Additionally, the Company coul-d have considered some
of the various modul-ar diesel generators on the market
that range in size from 15kW up to 2MW, incl-uding mobile
generators that can be transported throughout the service
territory. Such generators can be utilized during
maintenance of infrastructure and servicing unplanned
outages, while al-so providing support for essential
services throughout the Company's service territory in
the event of emergencies.3s
A 2013 FEMA press rel-ease highlights severa.l- of the
benefits these modular dj-ese1 generators can provJ-de to
communities.36 For example, the City of Seaside Heights,
NJ, originally purchased and install-ed three 2MW diesel
generators to provide services during periods of
peak-power demand at a cost of $a million. When
superstorm Sandy caused massive disruptions to the grid,
the city relied on these generators to power important
services in the communi-ty for 3 weeks. Unlike a new
redundant transmission that only would only benefit a
smal-l- portion of
ac _15 For example, a company with l-ocal distribution out of Pocatello
can sell a range of unconsidered alternatives:
http : / / www . generac . com/ indust ri a1,/ indus t ri al- - s olut i-ons /muni clpal
#resu.l-ts. The graph provides a range of al-ternatives based on size of
generator. Exhibit 315.
3 6 https :,/,/www. f ema . gov,/news -rel-ease /2 0 1 3 / 0 6/ 2 1 /emergency-
qenerators-power- es-ashore. Exhibit 316.I 25
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Idaho Power customers during exceptionally rare events
(assuming the l-ine itself is powered), these diesel
generators can provj-de numerous benefits across the
service terrj-tory and increase resili-ency in ways that
duplicative transmission simply cannot.
IGNORED COMBINATIONS. The analysis of DERs also
suffers from the false presumptions that only one source
of alternatj-ve energy can serve a system at a time and
that one source of energy needs to serve the entire load
at any given time. These are artificially high standards
of performance.
Because of the faj-lure to analyze DERs in
combination with each other, the analysis provides
incomplete conclusj-ons about DERs' potential to
temporarily meet the need during rare outages. Eor
example, a val-uab1e combj-natj-on that could have been
analyzed but was not is some distributed battery storage
and some limited amount of local- generatJ-on. The Company
also neglected to analyze the value of other reasonabl-e
combinations of distributed resources, including
employing existing customer owned and new backup
generation and targeted efficiency efforts in the NWRV
area.
IGNORED BENEFITS.fn the analysis the Company
system benefits that some of theperformed, they ignored
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IDAHO S]ERRA CLUB
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IDAHO S]ERRA CLUB
a1ternatives could provide and just 1ooked at capital
costs. The comparison of benefits is necessary to
understanding the fulI scope of options.
Some of the evaluated al-ternatives, such as battery
storage or some amount of emergency generator capacity,
could provide
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benefits to a larger portion of the publj-c than just
residents of the NWRV, who would be the only
benefi-ciaries of the redundant l-ine.
Outages caused by icing, micro-burst winds, fire or
avafanche are associated with specific reJ-atively
predictable conditions. When a heightened threat of such
an outaqe is predicted, resources l-ike storage could be
charged and held ready for backup service. At all other
times the storage cou1d be used for purposes like l-oad
shifting that provi-de a benefit to the general Company
customer community. Local emergency reserve generation
could provide simil-ar benefits to the general Company
customer set. The Company's analysis failed to recognize
these, or other, benefit streams in its evaluation.
In sum, the combined effect of these five major
deficiencies is that the Company produced a record
without adequate information upon which to determine
whether the proposal is cost-effective, 1et alone the
Ieast cost al-ternative among the options for providing
reliable and adequate service in the NWRV.
O. Do you think the analysls of distributed
energy resource al-ternatives ought to be redone?
A. Yes. A decision about the best way to
provide rel-iabl-e and adequate service to the NWRV cannot
be made until- we
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IDAHO S]ERRA CLUB
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IDAHO SIERRA CLUB
have a true understanding of the costs and benefits for
alternatives to a redundant transmission l-ine.37
The Commission authorized a technical- review
committee in the recent solar integration case when the
parties were having a challenging time seeing eye-to-eye
on the technical detail-s and val-ue assessments. The issue
of how to create l-ocal- resilience with rel-iable service
is complex and could benefit from a team of diverse
stakehol-ders following a similar process.
a. Would you consider such a technical- review
commj-ttee to be duplicative of the CAC process?
A. No, not at all. Sierra Club acknowledges
that the Company and WRV citizens
partlcipating in the CAC process.
that in light of the December 24,
residents have an understandable
rel-iabl-e power
spent many hours
We further understand
2009 outages, NWRV
concern
should be put
The CAC
on the need for
supply. But the resul-ts of
into appropriate context.
was not composed of members who
additional transmission; CAC
regarding a
the CAC process
were experts
members
provided expertise on
process was limited in
of siting a redundant
transmi-ssion Line
scope and focused
line, and the
siting. The CAC
on the details
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37 The Company itself acknowledges that the analysis was conceptual
and high-Ievel and insufficient to fully understand the costs and
benefits of integrati-ng DERs into the transmission system. Ange1l,
Exhibit 3 at 3 of 56 and 9 of 56.
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IDAHO SIERRA CLUB
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IDAHO SIERRA CLUB
"need" for the redundant line was presumed AS part of
that process.
o.What is your understanding about the CAC's
presumption that the redundant l-ine was "needed"?
A. Wh11e understandabl-e in the aftermath of
the 2004 Eagle case, from the very start of the CAC
process members were encouraged to associate "new
transmission" as needed for "rel-iabl-e power". The 2007
Wood River Electrical- PIan states, "The first step 1n
developing the proposed sol-utions to the el-ectrical- needs
of the Wood River Valley was to develop a Goal-s Document
that could be used to guide the commj-ttee's efforts to
develop and evaluate alternatives. " The first and second
of the six goal areas in that document were: (1)"Provide
reliable power to the entire Wood River Va11ey" and (2)
"Develop new transmj-ssion and delivery infrastructure as
appropriate when providing for current and future power
needs. "38
A decade l-ater, this direction by the Company that
"redundant transmission is needed" was more clearly
outlined in a letter to the CAC dated May 79, 20L6.
According to Idaho Power's letter:
More importantly, to truly improve thereliabi1ity and the quality of service to the
North Va1ley, a second, independent source for
energy, - a second 138 kV transmission fineis required. The second line has been needed
and in various stages of planning for25
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approximately 30 years. For various reasons,
primary
38 ZOOI Wood River Electrical Plan at 72, Exhibit 317.
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IDAHO S]ERRA CLUB
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IDAHO SIERRA CLUB
of which is l-ack of agreement upon siting a newline and the visual impacts of such, Idaho
Power has been unable to site and constructthis second l-ine into the North Va11ey.3e
The Company made it cfear that the CAC's role was
not to question the need for the redundant l-ine but to
agree on its route. As I stated above, the CAC members
were potentially mislead by the assertion that a second
13BkV transmissi-on l-ine would provide an "independent
source of energy" rather than just providing a redundant
method for getting energy from the single source (the
WDRI substation) should a situation arise where the
existing line would not be availabl-e.
Furthermore, statements from the Sun Va11ey
government show that the Company had a pattern of
asserting that the redundant line was needed, thus
Iimiting the scope of analysis for NWRV customers. Ms.
Tidwell, a party to this proceedlng, made the followj-ng
production request to the Company, which reads in part:
The Company's Application states at page 11that "Sun Va11ey stated that at the regularCity Council meeting of September 1-, 2016, thecouncil unanimously agreed that the redundantline project was necessary and vital for 1ts
community. . . " The Mayor of the City of SunValIey stated at the referenced meeting that,
"It is not a ote, it is an xpression of our
wishes as far as how they will- tackl-e thisproject that they are mandated to do toprovide us with power. They IIdaho Power I have
decided that they need to do this Iand]a 25
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IDAHO S]ERRA CLUB
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they are asking us to think about how we want
it done. "40
Thus, it appears that this presumption of need
significantly impacted the CAC process and l-imited the
analysis of redundancy alternatives that could also
provide reliab1e service to Sun Valley and the other NWRV
residents.
LOCAI V. GENERAI BEIIEFIT
O. Can you explain how the Company determined
the costs associated wlth undergrounding a portion of the
redundant l-ine and how the Company justifies recovering
those costs from al-1 ratepayers?
A. As the Company notes in their Application,
underground transmissj-on lines usually cost a significant
premium compared to overhead transmission, are more
difficult to service, and have a shorter lJ-fespan. The
Company also explains that the NWRV communj-ty has long
had significant concerns over vlewshed impacts and that
Iocal opposition has been a challenge for movlng forward
with the proposed redundant l-ine.
The various route options descrj-bed in the
Applicati-on presented al-ternative ways to site the
redundant line and compare
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40 ridwell Request For Producti-on No. \9, City of Sun Valley audio
transcript, September 1, 2016 at hour 1:45 (emphasi-s added). Exhibit
318.
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IDAHO SIERRA CLUB
undergrounding costs to a "base case" without
undergrounding. However, it
Idaho Power concludes that
is fess than clear to me how
ir
for the costs
is appropriate to charge
associ-ated withall ratepayers
undergrounding.
that the lowest
More specifically, it
cost ttbase casett was
is not clear to me
appropriately
selected or that the true costs of undergrounding and
how those wil-I be paid - are fuIIy understood at this
time.
O. Given your answer above, what do you
suggest in rel-ation to the assessment of local benefits
versus the general public interest?
A. As described above,
real concerns about the presumption
the Sierra Cl-ub has
that
"need" and that al-ternatives to address
redundancy is a
reliability were
not properly analyzed. Both of these issues cal-I into
question the validity of the methodology used to
ascertain the appropriate cost allocation between l-ocal-
and general ratepayers. As such, the cost analysis
warrants further consideration prior to issuing the
requested CPCN.
CONCLUSION
A. Please summarize your testimony simply.
A. The Company may prefer to build a
redundant transmission l-ine (which wil-I most like1y goI25
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into rate base at some time), but it has not demonstrated
its necessity or value to the public i-nterest.
HECKLER, Dr 31a
IDAHO SIERRA CLUB
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The Company has been pushing for this line for
decades, with recent activity ramping up since publishing
the 2001 Wood River VaIIey Electric Plan. Consider that
2007 is the same year the first iPhone came out and note
the astounding change mobile internet access has provided
in the last decade. The electric utility industry is al-so
facing a peri-od of dramatic technological change. Yet,
the Application seeks approval to buil-d a 70 to 80-year
asset to accommodate statistically unlikely outages in a
region that coul-d benefit from technological advances in
distributed energy resources. It is not in the public
interest to move forward on this construction project
without understanding what reliability requirements would
exist with a rebuil-t l-ine along the existing route and
thoroughly assessing how rapidly improving alternatj-ve
technologies could compli-ment NWRV service.
O. Does this conclude your testimony for now?
A. Yes.
HECKLER, Dr 32
]DAHO S]ERRA CLUB
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HECKLER, Dr-REB 1
IDAHO SIERRA CLUB
O Please state your name and business
address.
A Michaef Heckler at the Idaho Sierra Cl-ub,
503 W Franklln Street,
What is
Boise, Idaho 83702.
(,your rol-e at the fdaho Sj-erra
Cl-ub?
A I am the Chair of the Idaho Sierra Clubrs
Energy Committee.
O Are you the
direct
same Michael Heckler that
previously provided
Cl-ub in this matter?
testimony for the Idaho Sierra
A. Yes.
O. What is the
rebuttal testimony?
A. My rebuttal
S j-erra Club's response and
scope and purpose of your
testimony will
rebuttal- to the
provide Idaho
testimony
offered by Michael Morrison,
Utilities Commission Staff.
the witness for the Public
While we agree with a
testimonyr l we are
of
significant portion of Staff's direct
concerned about a potential misreading
1 For example, we agree that: (1) there is no compelli-ng
case for redundancy; (2) if the Commission deems a second
line necessaryr "cities,/counties" should be responsibleI25
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for footing the cost of any undergrounding of the line;
(3) the existing line is nearing the end of its useful-
life and shoul-d be rebuilt; and (4) using a temporary
shoo-fIy I1ne to provide power wh1le re-building the
existj-ng line can facilitate that re-building process.
HECKLER, DI-REB 1A
IDAHO SIERRA CLUB
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implicatj-ons based on that testimony. An example of where
a misreading might ari-se coul-d come f rom Staf f ' s
conclusi-on that local generation and storage options
exceed the costs of the Company's proposed transmission
l-ine.2 Some might read this quote to suggest that an
adequate review of distributed energy resources ("DERs")
has been conducted. We do not bel-ieve this is the case.
While DERs may not cost-effectively substitute for a
the data in the current record is basedredundant 1ine,
upon
for
unreasonabl-e assumptions rel-ated
DERs to back up entirety of 1oad,
to cost, the need
and the fail-ure to
Consequently, theconsider a combinatlon of resources.
record does not
applicability in
a combinati-on of on the existing
amount of DERs coul-dright-of-way combined with some
potentially supply reliabl-e electric service in the North
Wood River Va11ey ("NWRV"). Such a combination of
resources could provide reliab1e service at a lower cost
than the proposed redundant l-ine. We bel-ieve the current
record does not contain adequate information to support a
the " l-eastconc1usion that the proposed redundant line is
cost" or even a reasonable cost al-ternative.
2 Direct Testimony of Michae] Morrison at 25.
al-l-ow an adequate review of DERs or their
other re]evant contexts. We believe that
a rebuilt line
HECKLER, DI-REB 2
]DAHO SIERRA CLUB
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HECKLER, Dr-REB 3
IDAHO STERRA CLUB
Similarly, whil-e we are supportive of Staff's
request that a shoo-fly line be used to facil-itate
rebuil-ding the existing line, we do not think the record
contains adequate information to address concerns re1ated
to cost and routing of such a temporary 1ine. Alternative
siting options that have not been considered may save
money and address l-ocal concerns.
The implications of Staff's analysis show that the
Company's proposal, as it currently stands, is
insufficient to sofve the problems associated with this
docket. We assert that the record is missing necessary
data and therefore the Commission cannot determi-ne the
least-cost or most cost-effective alternati-ve unfess and
until we have additional data. As we proposed in our
direct testimony, a technical review committee may be
effective in collecting the data needed to determi-ne
whether there is a l-ower cost alternative that has not
yet been considered.
O. What are some of the public's interests in
addressing these data defj-ciencies?
A. One of the publlc constj-tuencies that
deserves resol-ution of a process they started in 2001 is
the Community Advisory Committee appointed by Idaho Power
(the "CAC"). Without additional data being added to this
record, the issues the CAC worked on cannot be adequately
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The CAC did the best they could within the confines
of the process they were given and the problem they were
tasked to solve. As I noted in my direct testimony, the
CAC was not tasked with analyzing the technical need for
a redundant line or technol-ogica11y feasible al-ternatives
to redundancy, but instead focused on siting and land use
issues for a redundant line that was presumed necessary
from the beginning.
The members of the CAC worked hard for many years to
serve the public interest, and they deserve some
resolutj-on for their efforts. It is not enough to give
the Company's CPCN request a slmple "thumbs up" or
"thumbs down" the public interest to which the CAC was
dedicated wil-l- be better served by a broader discussion
on afternatj-ves to redundancy. And Staff's testimony
could be construed to stand in the way of that
discussion.
a. Why do you think Staff testimony could
constrain a broader discussion?
A. In his direct testimony, Mr. Morrison
states, "The questions before the Commissj-on are: 1) j-s a
second line needed? 2) If so, what facil-ities are
necessary? 3) Vfhat costs shou]-d be borne by the general
body of Idaho Power ratepayers?"3 We believe a review
l-imited to these questi-onst25
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HECKLER, D]-REB 4A
IDAHO SIERRA CLUB
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is too narrow and that Staff testimony inherently extends
beyond these bounds. An appropriate review of
alternatives implied by Staff's analysis is necessary to
resofve the fundamental question of what alternative
makes the most technical and economic sense to continue
to supply rel-iable electric service in the NWRV.
n How would you rework the framing of those
analysis ?questions to J-mprove
A. Staf f suggested that some investments may
be warranted in the NWRV system but concl-uded that the
Company failed to prove that a redundant l-ine was needed.
Thus, w€ bel-ieve that it is necessary to more thoroughly
define what facilities, j-f any, are needed in lieu of a
redundant }ine.
0. Can you give an example of what might have
been different if the analysis had focused on
al-ternatives in lieu of the redundant line?
A. For instance, Mr. Morrison stated,
"Nevertheless, a second line wil-l- be necessary to
f acj-l-itate repair of the existing transmission l-ine. "4
We agree that a temporary "shoo-fly" l-ine is 1ike1y to be
an excell-ent alternative for providing service while
repairi-ng the existing
4 Morrison Direct at 3
the
HECKLER, DI-REB 5
IDAHO STERRA CLUB
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line.s However, the current record lacks information
about alternatives for routing
asks the Commlssion to direct
the temporary
the Company to
to the Efkhorn
line Staff
build (such
substationas routing the temporary
rather than the Ketchum substatlon) .
This gap in informatj-on is
because Idaho Power denies the
especially problematic
val-ue and practicality of
to its perceived faults,
Iine
the temporary
which include
shoo-f1y
problems
Staff' s
l-ine due
caused by routing through Ketchum.
for Production No . !4,
shoo-f1y
single
(iii)
line;
In response
which asked
Ketchum, Mr
Request
about runnj-ng a shoo-fly from Hailey to
Angell listed what he considered to be five
with that option: (i) wasted costs when
to
problems
line is
event taking
sti11 exposed
removed; (ii) still exposed to risk of a
(iv) still have
associated with
on single rebuil-t
same siting j-ssues
the permanent downtown Ketchum overhead
route"; and (v) difficulty justifying spending $50-B0k
each for L2 steel angle structures for a temporary line
" great ly
s In my direct testimony (see chart on page 22), I
>$25 million savingspresented j-nformatlon regarding the
out the non-redundant rebuil-t line;
for maintenance
"most of the
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availabl-e for: (1) a rebuild plus a redundant line versus
(2) a rebuild plus a shoo-fIy l-ine.
HECKLER, Dr-REB 6a
IDAHO SIERRA CLUB
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increasing the
sofution"5 We
analysis could
o.
option has been
in the current
A.
Request for Production to
Company was asked whether
non-recoverabl-e cost of this
bel-i-eve a properly conducted
( shoo-f1y)
alternatives
Company No. 15, the
ever presented with
address Mr. Angel1's concern.
Do you see other reasons why the shoo-fIy
undervalued and insufficiently analyzed
record?
Yes. fn Rock Rolling Properties LLC's
Idaho Power
the CAC was
the temporary shoo-fIy option. Mr. Ange1l's response was,
"No, this option was not presented to
inconsi-stent with the reliability goal
of the Wood River Electrical
the CAC as it is
found in Appendix
Plan. It states,C, page 6
'Provide
Wood River Va11ey. r"7 That
redundant transmission facilities throughout the
(first published
first step in devel-oping
page
"TheDecember 2007 ) states that
proposed solutions to the el-ectrical- needs of the Wood
River Valley was to develop a goals document to guide the
committee's efforts to develop and eva1uate
al-ternatives. " The first bullet under the heading
"ReIiabl-e Power" l-ists as a
6 Company's Response to Staff's Request for Production
No. L4, Exhibit 319.
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514
7 Company's Response to Rock Rolling Properties, LLC's
Request for Production No. 15, Exhibit 320.
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HECKLER, D]_REB B
IDAHO SIERRA CLUB
goal, "Provide redundant transmission facilities
throughout the Wood River Valley". B
This displays another example of how, by design, the
CAC was not presented with or asked to consider
alternatives to redundancy. Redundancy was the stated
goal and the CAC was not al-l-owed to veer off that path.
O. Do you think Staff properly analyzed Idaho
Power's approach to handl-ing the limited risk associated
with unlikely but catastrophic events?
A. Not entirely. As I explained in my dlrect
test j-mony, in the past 31 years there hasn't been a
single December or January outage caused by the
Hailey-Ketchum l-ine that lasted more than 10 minutes and
there is no seasonal pattern in the unplanned outages
that have occurred. When ldaho Sierra Club asked how the
Company would respond to another outage on both the
Hagerman and Gooding lines, the Company said that if both
lines feeding the WDRI substation go down they woul-d
"restore service as quickly as possible following prudent
utility practices of testJ-ng, isolating
B Wood River Efectric PIan Appendix C at Page 6, Exhibit
321.I 25
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rDAHO SIERRA CLUB
fail-ed device (s), restoring the remaining system and
repair or replacement of the failed device (s) . "9
We take from this response that the Company would use
best practices when faced with a low probability event
l-ike a simultaneous outage on both the l-ines feeding the
WDRI substation. When the Company performed their
"analysis" of DERs as alternatives to bui1ding a
redundant line they assumed that aII l-oad must be
backed-up. But, based on my discussions with an INL
expert, best practices call- for backup focused on
crltical- l-oads when faced with very low probability
outages. As it was explained to me, when the outage
probability gets down to "five ni-nes" (meanj-ng a less
than 99.9992 probability of occurrence, such as the
existing Hailey-Ketchum l-ine has provided), best practice
focuses on backing up critical loads under those
conditions rather than all load. The expert al-so noted
that some national- security related systems such as radar
or missil-e defense systems warrant a total load back-up
approach even at that low outage risk level-. Thus, total
load back-up for the NWRV may not be a necessary or cost
effective pursuit in the context of preparing for some
low probability outage events.
9 Company's Response to Idaho Sierra Club's Request forProduction No. 9, Exhibit 322.I 25
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HECKLER, DI-REB 1O
IDAHO SIERRA CLUB
We bel-ieve the
from some additional-
record would benefit substantialJ-y
information showing how to address
events with a combination of a
the existing l-ine route supplemented
sources of generation and/or
of such alternatives j-s necessary
and benefits of the redundant
the unlikely
rebuil-t line
phrasing
is vital
with some local backup
storage. Consideration
to understand the costs
limiting the
costs between
outage
along
of the third question
that we consider both
line the Company has proposed and whether a redundant
line is in the public interest.
O. Are you concerned with any elements of
Staff's analysj-s related to the third question, "What
costs shoul-d be borne by the general body of Idaho Power
ratepayers ? "
A. Yes. I have concerns that both cost
effectiveness ("least cost") and cost al-l-ocation analyses
are inc1uded in Staff testimony. Rather than just
review of cost matters to the allocatlon of
local and general ratepayers (as the
j-mplies to me), I think it
cost allocation and cost
effectiveness issues.
Do you see fl-aws in the Staff's conclusion
that DERs are not cost effective?
A. Yes. Mr. Morrison's testimony provides a
conclusion regarding DERs that coul-d be misconstrued. He
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HECKLER, Dr-REB 10a
IDAHO SIERRA CLUB
says, "CAC members requested that the Company evaluate
options asvarious loca1 generatj-on and storage
to a redundantalternatives
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l-ine. These options incl-uded diesel generat j-on, gas
turbine generation, biomass generation, solar generation,
and battery back-up. The Company determined that the
costs of each of these options exceeded the costs of the
Company's proposed transmission line. I concur with the
Company's assessment. Eurthermore, as I noted earlier,
there i-s no compelling case for redundancy.r'10
Irrespective of whether Mr. Morrison bel-ieves DERs
are an appropriate alternative t.o a redundant l-ine, they
shoul-d at l-east be reviewed as: (1) a method f or limiting
the harm that coul-d be caused by unlikely but
catastrophic outages (sabotage, plane crash, earthquake) ;
and (2) a supplement to the reliabil-ity provided by a
rebuilt existing line.
O. Please explain the problems with Mr.
Morrisonrs concl-usion that DERs exceed the costs of the
Company's proposed transmission l-ine.
A. A major problem I see is that the
Company's analysis upon which Mr. Morrison relies in
making his concl-usj-on fail-ed to consider the value of
benefits that installing DERs (e.9. generators or
storage) could provide both in the NWRV and to the larger
system. Such investments can mitigate the severity of
outages that do occur and as such
HECKLER, DI_REB 11
IDAHO SIERRA CLUB
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HECKLER, Dr-REB 11a
IDAHO S]ERRA CLUB
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HECKLER, DI-REB 72
IDAHO STERRA CLUB
are a viable option for the Company to reduce the "hurt"
caused by impacts from outages. Shortening the duration
and/or location of outages is a cost-effective method for
reducj-ng impacts.
Indeed, when it is
considered alternatives
in the Company's interest 1t has
that would address the impact of
Morrisonoutages rather than
notes, fdaho Power
Distribution route
their ellmlnation. As Mr.
the frequency of
outage events but
Compared to
only be useful- in
coul-d decrease their duration. "11
a redundant transmission line that would
a narrow set
explains that the
will- not decrease
Overhead
of circumstances, DERs can
benefits that do not
concl-usion are: (i ) the
SCTVE
appear
multiple purposes. Other
to be valued in Staff's
potential- use of DERs
agaj-nst future voltage
projected to be needed
(ii) providlng ongoing
shifting and emergency
as offsets providing savings
control improvements that are
at the Ketchum substation;72 and
grid servi-ces l-ike peak power
power.
o Do you
Ieast
have concerns with the cost
allocation and cost analysis Staff performed?
11 Morrison Direct at 2l (citing Appllcation at 22) .
72 Company's Response to Idaho Sj-erra Cl-ub's Request for
Production No. 5, Exhibit 323.I 25
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A. We agree with Staff in pointing out the
inappropriateness of using the Company's "standard
overhead distribution" as the baseline against which to
compare
l-ine. We
redundant
the cost of a partially overhead/partially buried
also agree with the
Iine be approved,
conclusion that should the
the benefitted cities/
counties shou]d bear the fuIl cost of aesthetic
mitigations such as undergrounding. But
Idaho Power can show that their proposal
l-east-cost (or even the most reasonable
we don't believe
presented
is the
cost) option
were based upon
the need for redundancy has
of questions ( "What
body of Idaho Power
just in the light
between all
more generally in
for general
the NWRV. In his
because
building
not been
ratepayers to
testimony Mr.
the only options
redundant l-ines
shown
they
and
Item #3 on Mr. Morrison's l-ist
costs shoul-d be borne by the general
rate payers?") needs to be viewed not
of an appropriate allocation of costs
ratepayers and benefitted loca1s, but
the context of what is a reasonabl-e cost
ensure rel-iable service to
Morrison states, "the burden is on the
Company to show that its
it represents the l-east
is necessary, and that
means for providing
proposal
expensive
rel-iable electric power to its customers."13
HECKLER, DI-REB 13
IDAHO SIERRA CLUB
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HECKLER, DI-REB 13a
IDAHO SIERRA CLUB
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HECKLER, D]_REB L4
IDAHO SIERRA CLUB
Mr. Morrlson also states, "In short, a second Wood
River-Ketchum line is a very expensive means to achj-eve a
rel-atively small reliability improvement."l4 We agree.
The record simply does not have the information necessary
to properly conclude that any option presented by the
Company is the least-cost or most cost-effective optJ-on.
I assert that this docket does not support a conclusion
that any of the discussed options are the least-cost or
most cost-effectj-ve because significant, necessary data
is missing. The results of a properly designed study,
perhaps Ied by a technical- review committee, will tell- us
whether there is a lower cost al-ternative that has not
been considered. Until data on the cost and benefits of
alternatives such as rebuilding the existing line and
supplementing it with some combination of DERs to
mitigate the effects of Iow probability outages is
provided, the Company's proposal cannot properly be
characterized as the l-owest-cost al-ternative.
O. Pl-ease summarize your rebuttal testimony
slmply.
A. We agree with Staff testimony on many
points incl-uding that: (1) there is no compelling reason
to buil-d the proposed redundant l-ine; (2) that the
existing
should be
l-ine is nearing the end of its useful- life and
rebuil-t; and (3) that it makes sense to use ao25
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temporary shoo-f1y line to provide power
1.4 Morrison Direct at 11.
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HECKLER, DI-REB L4a
IDAHO S]ERRA CLUB
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HECKLER, DI-REB 15
]DAHO SIERRA CLUB
whll-e re-building the existing line. We previously
testified that re-building the existing line (including
the cost of the temporary shoo-fIy line) is much more
cost efficient than both building the proposed new line
and re-building the existlng line.
We also agree wlth Staff's contention that even if
the existing l-ine is rebui1t there remaj-ns some resldual
reliabil-ity risk based on Iow probability events.
However, we think Staff's analysis of DERs
inappropriately ignores val-ue avail-abl-e from some smaller
amount of local- generation and storage than the Company
reviewed. Especially if focused on supporting critical
loads, loca1 DERs combined with a re-buiIt line could
provide the
reliability
probability
Staff
most cost-effective method for addressing the
implications assocj-ated with the type of l-ow
outage events.
identifled the probl-em but did not suggest an
analysis of a1ternatives. We think that represents a
mistake. The Company asks that the Commission find that
the redundant line is "necessary". We don't think the
record supports such a finding, but simply giving a
"thumbs-down" to their request seems an j-nadequate
resolution. The CAC members worked diligently to address
NWRV reliabifi-ty concerns, but the CAC process was run in
such a way that it effectively only addressed redundanto25
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HECKLER, Dr-REB 15a
IDAHO SIERRA CLUB
line based solutions. We believe both the CAC and the
larger
docket.
public deserve a different resolution to this
The data currently 1n the docket do not support
the analyses needed to resolve the
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HECKLER, DI_REB 16
IDAHO SIERRA CLUB
open
Cl-ub
cost and benefit issues l-isted above. Idaho Sierra
believes the public interest would be best served by
advisory
data needed to
directing
council or
the establ-ishment of a technical
other mechanism to col-l-ect the
resolve these issues.
O Does this conclude your rebuttal testimony
for now?
A Yes.
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CSB REPORTING
(208 ) 890-s198
HECKLER
Idaho Sierra Cl-ub
(The following proceedings were had in
open hearing. )
MS. NUNEZ: Thank you. Mr. Heckler is now
able for cross-examination.
COMMISSIONER ANDERSON: Thank you. Does
the Applicant have any cross?
MR. WALKER: I apologize, Mr. Chairman,
dj-d we spread both direct and rebuttal- for Mr. Heckler?
MS. NUNEZ: That is my
COMMISSIONER ANDERSON :
I didn't have that in there. We are
request.
Yes,
doing
I apologize.
that, yes.
no questionsMR. WALKER: Thank you, and
from Idaho Power.
our list. Mr
COMMISSIONER ANDERSON: We'l-l- go down on
Adams.
MR. ADAMS: No questions.
COMMISSIONER ANDERSON: Mr. Richardson.
MR. RICHARDSON: f have no questions,
Mr. Chairman.
COMMISSIONER ANDERSON: Mr. Arkoosh.
MR. ARKOOSH: No questions. Thank you.
COMMISSIONER ANDERSON: I should actually
ask again, Laura Midgley
City of Ketchum?
never showed up, did she? Okay,
MR. JOHNSON: No questions.I 25
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CSB REPORTING(208) 890-5198
HECKLER
Idaho Sierra Club
COMMISSIONER ANDERSON: Did I miss any
i-ntervenors? Staf f
MS. HUANG: No quest j-ons .
COMMISSIONER ANDERSON: Commissioners?
Thank you. No redirect.
MS. NUNEZ: Thank you.
(The witness left the stand. )
MS. NUNEZ: I'd ask for him to
but I think he would l1ke to stay.
COMMISSIONER ANDERSON: Thank
be excused,
you for your
wish to
aIso.
testimony.
be without
are we dt, City of Ketchum?
MR. JOHNSON: Mr.
Iike to cal-l- Mayor Nina Jonas.
I guess you could be excused if you
objection and you're welcome to stay,
THE WITNESS: Thank you.
(The witness left the stand. )
COMMISSIONER ANDERSON: Letrs see, where
Chairman, the City would
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CSB REPORTING
(208 ) 890-s198
JONAS (Di)
City of Ketchum
produced
Ketchum,
the whole
NINA JONAS,
as a witness at the instance of the City of
tel] the truth,having
truth,
been first duly sworn
and nothing but the
f o1l-ows:
to
truth, was examined
and testified as
THE WITNESS: Thank you, Commissioners,
for your devotion to your state
here to help us all- with heal-th
and your abiJ-ity to be
safety.
COMMISSIONER ANDERSON: Welcome here.
DIRECT EXAMINATION
BY MR. JOHNSON:
O So Madam Mayor, if you would please state
your name for record.
A Nina Jonas, N-i-n-a J-o-n-a-s.
O Okay, and your tit1e,
City of Ketchum?
A Mayor City of Ketchum.
O And you've previously
position with the
filed testimony,
approximatelyrebuttal testimony, on June 23rd, 2077, of
seven pages; is that correct?
A Yes.
O And do you have any clarifications,o 25
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CSB REPORTING
(208 ) 890-s198
JONAS (Di)
City of Ketchum
updates, ox additions with respect to your concerns in
that testimony about rel-iability and resiliency?
A Yes, the R-3, the R-cubed, reliability,
resilience, and redundancy.
MR. JOHNSON: So Mr. Chairman, j-f we coul-d
al-Iow her those addltions to the testimony at this tj-me.
COMMISSIONER ANDERSON: Pl-ease conti-nue.
THE WITNESS: Thank
bit about that today
challenges
of Ketchum
you. I think you've
in the mul-ti-decadeheard quite a
hj-story of the
the community
Power and have
I think at the
resilience and
that we face and the
have worked hard with
city and
Idaho
come a long way. Thank you, Idaho Power.
baseli-ne is the assumptions of what
rellability are and as you can hear, the
are posed, you know, reliability to thechallenges that
community of Ketchum and many of the representatives is
reaJ-1y the issues
the community for
outages have been
of getting energy to
heal-th and wel-l-ness,
down in
community --
and our power
to
Idaho Power to talk about
immediately goes where the
and --
the desert, so when we come to
redundancy, the i-ssue
power is being generated
MR. WALKER: Excuse me, Mr. Chairman,
excuse me, I object to live direct/cross-examination on
new few issues that weren't incl-uded in the prefiledt25
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CSB REPORTING(208) 890-s198
JONAS (Di)
City of Ketchum
direct testimony. This was under the nature of any
corrections to her prefiled direct testimony and there's
been no specific motion nor authorization to present new
l-ive direct testimony and puts everyone else at an unfair
advantage. We were al-I required to prefile our
testimony.
COMMISSIONER ANDERSON: Would you like to
comment?
Mayor if she had
. JOHNSON: So Mr. Chairman, I asked the
clarifications or additions based on
updated
that's
circumstances. That was the request and I thlnk
what she's getting towards. The nature of her
testimony is a littl-e different as a public official-
versus an engineer or otherwise, so I request a little
bit of flexibility here. She's not able as a public
official to testify in the public hearing, because the
City is an intervenor in the matter, so a l-ittle
flexibility here. If you would 1ike, I'm more than happy
to ask her to get directly to some of the current
cj-rcumstances that rel-ate to the update in the testimony
that was previously filed.
COMMISSIONER ANDERSON: WeII, I have to
agree with Mr. Walker that it does create an unfair
advantage to the other intervenors. If you can direct
her to get where she needs to be, that woul-d be great.
MR
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CSB REPORTTNG
(208 ) 890-s198
JONAS (Di)
City of Ketchum
O BY MR. JOHNSON: So Mayor Jonas, if you
couId, could you just update with respect to current
events from this past weekend and how they rel-ate to the
previously-stated concerns on reliability and
resiliency?
A One of our maj-n reliabil-ity issues that
was thrown to the community
a fire out in the desert in
community was alerted by
Sheriff's Department that
power outage, getting to
reliability issue is the
succinct as I can be.
O Are there
this last weekend was there's
Shoshone,and so Saturday the
through the
having a 48-hour
that the real-
Idaho Power
we might
the point
be
power source. That's as
any other updates or additions
to your previously-filed testimony that you wish to bring
up at this time?
A Well, from the hearing this morning, the
issue of the cost of undergrounding.
MR. WALKER: Mr. Chairman, I object. This
is not appropriate to be correcting testimony when laying
a foundation to admit prefiled direct.
MR. JOHNSON : V{e ' II move on.
MR. RICHARDSON: Mr. Chairman, Peter
Richardson here. I don't really want to interject, but
it's my understanding that one of the Code sections thatIZ5
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CSB REPORTING
(208 ) 890-s198
JONAS (Di)
City of Ketchum
fdaho Power filed its application is pursuant to Idaho
Code Section 67-6528, which provides that this Commission
is obligated to give affected governmental- agencles an
opportunity to appear before or consul-t with the Publ-ic
Util-ities Commission, and I believe that the Mayor as
representing an affected governmental agency has an
independent right to consuft and appear before this
Commission irregardless of whether or not prefiled
testimony has been made.
MR. WALKER: And Mr. Chairman, Idaho Power
does not disagree wlth any of
been represented by
those statements and the
Mayor has counsel.Actually, the
counsel with theCity of Ketchum has been represented by
Mayor being their witness and has had every opportunj-ty
that everyone else has had to fully participate in these
proceediflgs, and this is simply a matter of following the
proper decorum and the Commission's rufes on the
presentation of evidence that we al-l- had to fol-l-ow.
COMMISSIONER RAPER: Well, so recognizing
here, Mr. Johnson, that there's a 1ot of people in the
room who are here al-l- the time and yourre not, and so
this is somethi-ng that is unfamiliar territory to you.
It's fairly standard for the rest of us and because our
process and procedure has a prefiled opportunity, a
rebuttal opportunity, and in this case surrebuttal-I 25
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CSB REPORTING(208) 890-s198
JONAS (Di)
Clty of Ketchum
opportunity,
here and we
there is a lot of information on the record
do appreciate and I believe we are consj-stent
with the statute in having al-l-owed the Mayor to be a
witness for the City of Ketchum.
With that said, f think that Idaho Power
woul-d be willing to offer some latj-tude in shaping the
record from what the testimony has been up to this point.
There has been a l-ot of 1atitude given to other witnesses
and other attorneys here for what the questions are
related to and how far they go, but recognize the way
that this works for us with prefiled, itrs different than
probably any scenario you're used to, and it is an unfair
advantage when nobody else here gets an opportunity.
MR. JOHNSON: Wel-l, ds I said, the purpose
and the request the Mayor had was to provide some updates
and additions, which has been provided throughout based
upon recent events that were not avail-ab1e at the time.
It's not trying to get beyond that or drop new evldence
on somebody. It's not like she has englneering reports
t.hat nobody is going to get a chance to see, but I'm
happy to stay within whatever parameters the Commission
woul-d --
COMMISSIONER RAPER:If you'I1 keep it
think thatwithin the scope of the record,
MR. JOHNSON: f thi-nk at this point we'll-
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CSB REPORTING(208) 890-s198
just move on and I would --
O BY MR. JOHNSON: So Madam Mayor, would you
provide the same answers if I asked you these same
questions from your June 23rd testimony if f asked them
today?
A Yes.
MR. JOHNSON: So I will move that the
prefiled testimony of Mayor Jonas be spread across the
record.
COMMISSIONER ANDERSON: Thank you, Mr.
Johnson, and if you're new at this, I'm even newer.
MR. JOHNSON: I appreciate that.
COMMISSIONER ANDERSON: And f'm grateful
bit when Ifor my other Commissioners 1ittle
need it, because I need it
to help me a
a l-ot more than f realrzed,
and Madam Mayor, I appreciate you bei-ng here and we do
recognize that you have a larger and broader compass than
just yourself. You're elected, you have a constj-tuency
and this Commission is fu11y aware of that and it wil-I
not be l-ost on us when we deliberate, so we have a motion
before us and I see no objections. The testimony is
spread across the record.
testimony of Ms
(The following
Nina Jonas is
prefiled rebuttal-
spread upon the record. )t 25
591 JONAS (Di)
City of Ketchum
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O. Please state your name and office within the
City of Ketchum.
A. My name is Nina Jonas. I currently serve as
the Mayor of the City of Ketchum. I was elected as Mayor
in 2073 and prior to that served on the City Council from
2009-2013. Sustainability and energy efficiency have
been important parts of my leadership pJ-atform and
efforts at the City.
O. What is the purpose of your rebuttal- testi-mony?
A. My rebuttal testimony wilJ- clarify the position
and concerns of the City of Ketchum with respect to items
raised in direct testimony. I will also respond to
direct testimony related to the issue of whether Idaho
Power has appropriately and adequately evaluated
al-ternatives in this matter. I wil-l- also respond to
arguments raised in direct testimony related to burdening
municipalities with the costs of the proposal-.
O. What are the City of Ketchum's interests and
concerns in this proceeding?
JONAS, REB 1
City of Ketchum
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JONAS, REB 2
City of Ketchum
A. The City of Ketchum ("City") is concerned with
issues in the proposal of fdaho Power Company ("Company")
as related to protecting land usage, scenic values, and
the unique nature of the area. Additionally, the City
joins in the concerns of other intervenors in this
matter, such as in the
Heckler, related to the
direct testimony of Michael
consideration and revi-ew
Company's insufficient
of alternatives to a redundant
transmission line. The City has formed an advisory
committee known as the Ketchum Energy Advisory Committee
( "KEAC" ) specifically to advise the City on energy j-ssues
with a particufar focus on striving toward increased use
of renewable energy, conservation, and effici-ency.
Resolution 14-005 of the City of Ketchum specifically
identifies a purpose of forming the KEAC is to reduce the
carbon footprint of the community and become a greener
community.
To that end, the City and KEAC have focused on
evaluating new energy technologies and methods of
promoting energy efficiency to reduce the need for more
resource-j-ntensive energy production and distribution.
The City is quite interested in this proceeding for the
purpose of making sure the Company does not simply answer
every energy questJ-on with a proposal to build more
"sticks and wiresr " but instead conduct a truet25
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consideration of alternatives. The City joins with the
interest of intervenors such as the Sierra CIub of Idaho
in questioning whether the Company has truly evaluated
and considered alternatives and feasibility costs that
can achieve goals of resiliency and redundancy without
simply reverting to building more lines.
O. Does the City believe the Company has
adequately and appropriately considered al-ternatives to a
redundant transmission l-ine?
A. No. The City does not bel-ieve that the Company
has appropriately addressed or investigated a true
cost-benefit analysJ-s of alternatives, including
consideration of l-ocal generation and micro-grj-d
alternatives. The City disputes the Company's contention
that such
JONAS, REB 2a
City of Ketchum
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alternatives woul-d "greatly exceed the cost of the second
transmission line. "1
The City has previously commented as to the need for
more details and independent analysis of reliabil-ity via
loca1 alternatives.2 An analysis of cost-effective
solutj-ons needs to take into account not just immediate
needs but future trends and adaptabilj-ty to more
contemporary approaches to energy production and
distribution. Better grid integration, accommodatj-on for
growing l-ocal generation trends, and consideration of
storage deserve a true independent analysis as these
opti-ons become more common and more cost-effective. The
City has previously commented on such and provided a
potential proposal for such an analysis.3 Those comments
and proposal are hereby referenced and reincorporated by
this testimony. This need for an independent analysis
continues to be overl-ooked by the Company and is
overlooked or summarily dismissed without argument in the
dj-rect testimony of Company representatives.
Additionally, the testimony of IPUC staff engineer
Mike Morrison recommends against a redundant transmission
Iine as an immediate need, instead recommending
reconstructj-on of the existing line and use of a
temporary l-ine.a This further indicates that there need
not be a rush to dismiss al-ternatives without independent
JONAS, REB 3
City of Ketchum
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JONAS, REB 3a
City of Ketchum
analysi-s or for ldaho Power to significantly invest in a
less than compelling line construction that is
unnecessary in the present and not designed to
accommodate the future. Technological changes require
better analysis of al-ternatives than has been provided by
the Company in this matter.
The City of Ketchum concurs and supports the
assertion of Mr. Heckler in hls dj-rect testimony: "We
believe that a more robust consideration of al-ternatives
is in the public interest and that a combination of a
rebuil-t Iine along the existing right-of-way with some
grid edge
1 Application at 11.2 City of Ketchum Comment Letter, dated Oct. 4, 2076, already on file
in this matter.3 ta.4 t,toRRtsoN Dr at 3 and 22.I 25
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resource alternatives can provide excel-l-ent resiliency at
a lower cost. . . "5
O. Does the City support the Company's stated goal
of increased reliabllity?
A. Yes, the City shares in the concerns and goals
related to increasing energy reliability, as well as
energy efficiency. However Mr. Heckler in his testimony
outl-ines how the Company has confl,ated reliability with
redundancy, thus skipping over consideration of
al-ternatives to a redundant l-ine. This matches with the
City's concern that the Company has been in a rush to
judgment on this matter. The City's perception is that
the Company has jumped straight to constructing a
redundant line, while ignoring the record of reliability
on the existing line and the likelihood that
reconstruction with a temporary line more
cost-effectively achieves the needed reliability. As Mr.
Morrison's IPUC staff testimony attests, this
reconstruction option is more cost-effective while the
City al-so sees that option as having the benefit of not
overspending on an investment into traditional
infrastructure that may be iI1-suited to hand1e and
address reliabil-ity and efficiency in rel-ation to more
contemporary energy technology.
a. How does energy efficiency play into the goals
JONAS, REB 4
City of Ketchum
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of the City?
A. In forming KEAC the City specifically incl-uded
pursuing and promoting energy efficiency as a purpose and
goal. These energy efficiency goals contrast with the
Companyrs portrayal- of rising demand in this area.
Additionally, Mr. Hecklerrs testimony shows problems with
the Company's assumptJ-ons and portrayals with respect to
population growth, outage events, and load demand.
Again, the City believes the Company has speculated on
such projections 1n such a manner as to derive a desired
resul-t, rather than in conductj-ng a true analysis. The
victim of such speculati-on is again a discounting of
alternatj-ves and a rush to overbuilding of sticks and
wires, rather than evaluatj-on of cost efficiency and
technol-ogical adaptability for longer term future
reliability and efficiency.
5 gecxleR Dr at 1, l-ines L2-1,6.
JONAS, REB 4a
City of Ketchum
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The City concurs with
that these concerns about
the testimony of Mr. Heckl-er
projections, values, and
technology
committee
warrant consideration of a technical review
approach. The standard objection that such a
process
staff' s
line is
lengthens the time required is mitigated by IPUC
findings and recommendation that the existing
more rel-j-abl-e than portrayed by the Company. The
KEAC woul-d be interested in participating inCity
such a technical review commj-ttee as such goes directly
to the purposes and expertise for which the KEAC was
formed.
0. How woul-d the City like to respond to the
assertions about charging undergrounding j-ncremental
costs completely to the loca1 communities?
A. The Clty understands that there are options to
direct billing to affected rate payers by line item to
address a locaI community pressing for more costly
options for purposes l-ike aesthetics. However, the City
feel-s that undergrounding has been over-portrayed as
purely an aesthetics issue. fnsuffj-cient attentlon has
and
been paid to health, safety,
Engineering various overhead
and economic concerns.
lines will-not only impact
Ketchumthethe aesthetics and visibiJ-ity within
community, but poses safety risks and
an area where development already is
creates burdens in
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605 JONAS, REB 5
City of Ketchum
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space constraints. Aesthetics also become more
economically significant in an area where the economy is
heavily rel-iant on tourism and a certa j-n atmosphere.
Furthermore, undergrounding seems to provide practical
benefits to address many of the weather and
nature-related concerns that have been raised with the
existing l-ine.
The City al-so joins in the concerns raised in Mr.
Heckl-er's testimony that apportionment of costs onto the
local- communities is al-so irresponsibl-e at this time when
there are significant concerns about cost methodol-ogy.
There are disputes between the Company, staff, and
intervenors with respect to cal-culation of such costs and
even what should be the appropriate
JONAS, REB 5a
City of Ketchum
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base case. These technica] issues related to cost
deserve further review and anal-ysis before beginning to
order significant costs to be borne by the l-ocal-
communities.
O. What are the City's concerns with respect to
the testimony of Cox Communication representatives?
A. Staff and intervenor testimony contradicts the
testimony of Mr. Stul1 of Cox Communication that the
Company requires "badIy needed redundant facilities. " My
testj-mony already references the problems with a focus
purely on redundancy, particularly as proposed by the
Company, and raislng questions as to a judgment of "badly
needed. "
The City understands how co-location may be
desirabl-e. However the City does not support
overbuilding of redundant fines or overbuilding on a
repair of the existing line any more than absolutely
necessary to accommodate existing services on the po1es.
Heightening of poles should be restricted to a minimum to
preserve the character of these communities
Additionally, issues pertaining to co-location
should be of lower priority until the multj-tude of
technical- review concerns are addressed.
a. Pl-ease summarize your testimony on behal-f of
the City.
JONAS, REB 6
City of Ketchum
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JONAS, REB 6a
City of Ketchum
A. The City sees significant
analysis and recommendations between
differences of
Company, staff, and intervenors
matter. Those differences need
review; particularly where such
as to
the testimony of the
actual- need in this
resolution via technical-
technical- review provides
a better avenue to more fully and independent evaluate
al-ternatives and changing technol-ogies that better match
loca] priorities.
The City supports more sophlsticated analysis of
to rush intotechnol-ogical advancement
overbuil-ding traditional
and a reluctance
lnfrastructure just because that
is the way it has been done before.
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JONAS, REB 1
City of Ketchum
The City
respons ibi I it y
loca1 concerns
accepts that some level
for incremental costs
of 1ocal
to address purely
may be necessary, but believes better
analysis of
construction
such cost alternatives and actual- needed
is necessary before imposing such.
O
A
Does that conc1ude your
Yes.
testimony at this time?
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CSB REPORTING(208) 890-5198
JONAS (X)
City of Ketchum
(The following proceedings were had in
open hearing. )
MR. JOHNSON: So the witness is avaifabl-e
for cross-examination.
COMMISSIONER ANDERSON: Thank you very
much. Let's begin with the Applicant.
MR. WALKBR: No questions from Idaho
Power, Mr. Chairman. Thank you.
COMMISSIONER ANDERSON: Thank you. Mr.
Adams ?
MR. ADAMS: No questions.
COMMISSIONER ANDERSON: Thank you. Mr.
Richardson.
MR. RICHARDSON: No questions,
Mr. Chairman.
COMMISSIONER ANDERSON: Thank you.
Ms. Nunez?
MS. NUNEZ: I have a question.
COMMISSIONER ANDERSON: Yes.
CROSS_EXAMINATTON
BY MS. NUNEZ:
O Mayor Jonas,
about the possibility of a
we've talked a l-ot today
Iocal J-mprovement districtI
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CSB REPORT]NG
(208 ) 890-s198
JONAS (X)
City of Ketchum
being a financing mechanism if there are incremental-
costs imposed on l-ocal- jurisdictions. Can you please
comment on the likelihood that the governing body and
consti-tuents in the City of Ketchum wou1d approve a LID
according to the required statutory procedure if that was
proposed?
A Yeah, wel-l-r ds far as I understand, a LID
is a simple council vote, a simple majority. I hate to
speak for the councj-l-. They would hate for me to speak
for them. I do know that going through the process over
the l-ast year, we've also explored with Idaho Power
franchise payments and payments back to the rate users,
and I do bel-ieve that that would be much of a more
With our energy goals i-n the
that putting the price on users of the
the key elements that the council is
the LID puts it to the property
val-uer so I don't think it would do
with versus
wel1.
MS. NUNEZ: Thank you. No further
questions.
COMMISSIONER ANDERSON: Thank you.
Mr. Arkoosh.
palatable
community,
energy is
concerned
option.
I know
one of
value and not the use
MR. ARKOOSH: No questions. Thank
COMMISSIONER ANDERSON: Thank you.
you.
Staff?I 25
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CSB REPORTING(208) 890-s198
JONAS (Com)
City of Ketchum
MS. HUANG: No questions.
COMMISSIONER ANDERSON: Commissioner
Kj ellander.
COMMISSIONER KJELLANDER: The best part
about being a
questions.
Commissioner j-s nobody can object to my
COMMISSIONER ANDERSON: Try me.
EXAMINATION
BY COMMISSIONER KJELLANDER:
o You were
asked you
had and I
given a l-ittl-e bit of l-atitude
to really focus in on the recentearly
fire
and we
that you guess I
better.
litt1e
just want to try to
understand that a little There was a recent
paper, and you
in
fire. I read about it a bit in the
were told by the utility what specifically
rel-ationship to the transmission line and
48-hour outage?
the possible
A So we were al-erted through our reverse 911
cal-l-ed the sheriff and the
the River's 977 system and it
system and Idaho Power had
undersheriff had posted on
be planned forsimply
hours,
River
said a potenti-a1 power outage of 48
into the Woodbecause the transmission line coming
substation is under threat, and then we quicklyI25
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CSB REPORTING
(208 ) 890-s198
JONAS (Com)
City of Ketchum
I 25
613
called the Sheriff's Department to understand more
information before we put it out again, and we did not
get any more information, and we attempted to contact
Idaho Power and we could not, so we had a run on ice in
the City of Ketchum, and then the next I can't
remember 1f it was that night, I think it was next
mornJ-ng, Sunday morning, again, we had another 911
reverse cal-l- where it said the threat was over.
O Does the potential of threats l-ike that,
as you sdy, out on the desert, of course, more of a risk,
obviously, whatrs that tell you as a Mayor with regards
to the need or the lack thereof of a need for a redundant
line that woul-dn't necessarily be "on the desert"?
A Yeah, well, the proposal of the redundant
line, what concerns me is it's a bel-t and suspenders
option and the issue j-s we can't get the power if the
power is threatened, and the sustained power outages that
we've had, the power has been traumatj-zed bel-ow that Wood
River substation, so it doesn't resolve the true
reliabili-ty issue, and as far as that notice went, fly
biggest concern was it would cause a panic, because we
saw that during the Beaver Creek fire cause a panic for a
planned or be prepared for a potential evacuation,
because it's a narrow corrj-dor and we don't want people,
1ike, oD the highway when there's not a plan to manage
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CSB REPORT]NG(208) 890-s198
JONAS (Com)
City of Ketchum
that traffic.
COMMISSIONER KJELLANDER: Okay, thanks
COMMISSIONER ANDERSON: Commissi-oner.
THE WITNESS: Thank you for the question.
EXAMINATION
BY COMMISSIONER RAPER:
O I'm wj-th Commissioner Kjellander, see,
this is where you have an opportunity to speak a l-ittle
more freely, because I donrt think anyone in the room
wil-1 object. Along with where Commissioner Kjellander
was going with this, f 'm trying to reconcil-e in my brain,
it l-ooks like it's a viewshed issue to a l-ot of people,
this redundant line, and I'm trying to reconcile, Iike,
Mayor and City Council- and their positions on it versus
Sun VaIIey Company and, you know, they clearly have sai-d,
rror we need it, we want it. How do you reconcil-e that as
the Mayor and they're al-l- your constituents, businesses
and resj-dents al-ike, how do you reconcile the different
positions ?
A WeIl, I think it kind of gets down to the
definition of emergency and so our community is reaIIy
resil-ient and I think we're pretty proud of being
resilient and for me, the term resil-ient goes to aI25
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CSB REPORTING(208) 890-5198
JONAS (Com)
City of Ketchum
community and not necessarily an infrastructure piece, so
there's definitely a bit of an assumption problem there
when we start the conversation, so many of my
constituents want to see true resilience, which means
that there's an energy source that we can tap into when
the energy source is at risk.
Eor Sun Valley Company, and I don't want
to speak for them, they actually have testimony, most of
their property that they own is not in that view
corrldor, so they don't have that issue, but they do have
the issue of the chairlifts, and that takes a lot of
energy and when we had the power outage caused, again, by
the desert power for Christmas of 2009, that was where
they were hit economically, so from my perspective, I'm
concerned about water, sewer, fire, hospital, health
care, those heal-th and safety issues for emergency, and
then the businesses are more concerned about how much
lost revenue they're
Pioneer
going to have. One business
1oca11y, the
power outage,
Saloon, you may know it, after that
they went
the next
Pioneer,
power outage,
no problem.
O Why are
A Because
out and bought a generator, so
you can get your cocktails at the
you looking at me?
it's the one restaurant in town
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CSB REPORTTNG(208) 890-s198
JONAS (Com)
City of Ketchum
community, the majority of the plan is on the county, but
I mean, the property value in our area is astronomical
and our whol-e economy
property,
issue on
economy.
which does
OSo
and resilj-ency and
the public hearing
people want to be
but I want to know
I
is being buoyed up on this
create an enormous affordability
spades,
to be
got the message that the
another level-, but aesthetics do matter to our
hear you say response and emergency
I appreciate that and heard that at
l_n
abl-e
that you
and the
responsive in their own way,
and your constituency and the
businesses also understandpeople in
that Idaho
your town
Power has an obligation,
powerr So is it
a 1ega1 obligation,
that your residentsto provide
are willing
a period of
re1 iabfe
to make a trade-off and be without power for
time and kind of stick it out and go pioneer
and be tough or is it that you believe that the
reliability isn't negatively impacted by the current
circumstances ?
A Both, and a third. I think that our
community can stick it out. I think most of Idaho feels
that way. We're all about being independent and being
off the grid on some level-, right, that's why we live in
this state, so I think there's that, and then I a1so, I
think the community understands. This topj-c has beent25
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CSB REPORT]NG(208) 890-5198
JONAS (Com)
City of Ketchum
with us since 1995, very
chalJ-enges and has tried
discuss another option to
reliabil-ity aside from a
where the loggerhead has
this one solution and the
solution.
live and understands the
to work with Idaho Power to
providing that redundancy,
transmission line, and that's
come. You know, Idaho Power has
community is asking for another
There have been moments when Idaho Power
and the community have come together. In 2013, Idaho
Power offered the Wood River Renewabl-e Energy Working
Group to come up with sol-utions and those sol-utions kind
of fell- to the wayside, and I think actually one of them
was a community solar project that you got here.
O Speculation on your part, So they go a
totally, Idaho Power goes a tota1Iy, different route and
allows you build a DG, some dj-stributed generation up
there somewhere. You're still- going to have l-ines and
you're going to have the DG plant sitting there, who's to
say that there's not going to be people that are angry
about what that l-ooks like or where that's l-ocated?
A You can't please everybody, absolutely.
fn the preliminary conversations locally of how that
woul-d work, certainly, the siting of a substation either
for transmission or distribution to come into town is
still unanswered, and siting for a generation site is25
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CSB REPORTING(208) 890-s198
JONAS (Com)
City of Ketchum
unknown as wel-l-, but I mean, thatrs been kind of the
premise the City is coming from is can we tal-k about this
on a bigger scal-e so that we can talk about options and
reliability at the same time, because the transmissj-on
l-ine, ds you've heard over the last months, is very
challenging.
COMMISSIONER RAPER: Thank you. I
appreciate your time.
THE WITNESS: Thank you for your
questions.
COMMISSIONER ANDERSON: Mr. Johnson, any
redlrect?
MR. JOHNSON: No redirect.
COMMISSIONER ANDERSON: Thank you, and
Mayor Jonas, thank you so much for your testimony.
THE WITNESS: Thank you, and thank you for
your ass j-stance.
MR. JOHNSON: May I request that the Mayor
have permission to leave the rest of the proceedings if
she desires
COMMISSIONER ANDERSON: Wj-thout objection,
so qranted.
MR. JOHNSON: Thank you.
THE WITNESS: Thank you.
(The witness left the stand. )25
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CSB REPORTING
(208) 890-sl-98
MORRTSON (Di)
Staff
I
COMMISSIONER ANDERSON: Staff, we've moved
to you.
MS. HUANG: Yes, Staff ca1ls Dr. Mike
Morrison.
MICHAEL MORRISON,
produced as a witness at the instance of the Staff,
having been first duly sworn to tell- the truth, the who1e
truth, and nothlng but the truth, was examined and
testified as fo]lows:
BY MS. HUANG:
nY
please state
the record?
A
a
Good afternoon, Dr. Morrison. Could
your full- name and spell your last name
you
for
I am Michael W. Morrison, M-o-r-r-i-s-o-n.
Who is your employer and in what capacity
are you employed?
A I am employed by
Utltities Commission as a Staff
O Are you the same
direct testimony in this matter
101 through ll2?
the Idaho Public
engineer.
Dr. Morrison who prefi1ed
including Exhibit Nos.
25
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DIRECT EXAMINATION
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AI
ODo
that testimony?
AI
o rf
set forth in your
the same today?
I were to ask you those
direct testimony, would
same questi-ons
your answers be
am
you have any changes or corrections to
do not.
A They would be.
MS. HUANG: MT
Dr. Morrj-son's testimony and
. Chairman, T move to spread
Exhibits 101 through L1-2 on
the record.
COMMISSIONER ANDERSON: Seeing no
objectJ-ons, we'f1 spread the direct testimony and
Exhibits 101 through 172 on the record.
(The foll-owing prefiled direct testimony
of Mr. Michael- Morrison is spread upon the record. )
CSB REPORTING
(208 ) 890-s198
MORRTSON (Di)
Staff
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CASE NO. IPC_E-1.6_28
05/05/71
MORRTSON, M. (Di) 1
STAEF
O. Pl-ease state your name and address for the
record.
A. My name is Mike Morrison.My business address
Idaho.j-s 412 West Washington Street, Boise,
o
A
By whom are you employed and in what capacity?
I am employed by the Tdaho Public Utilities
Commission (Commission) as a Staff Engineer.
O. Please give a brief description of your
educational- background and experience.
A. I received a Bachelor of Science degree in
Chemical Engineering from the University of Southern
Cal-ifornia in 1983, a Master of Science degree in
Mechanical Engineering from the University of Idaho in
2002, and a Doctor of Philosophy in Geophysics with a
Civil- Engineering emphasis from Boise State University j-n
201-4. I have been a registered professional- engineer in
Idaho since 1998. I attended the Electrical- Utility
Baslc Practical Regulatory Program offered by New Mexico
State University's Center for Public Utilities.
Between 1988 and 2009, I hel-d a number of
engineering positions at Micron Technology, Inc. From
L990 through 7996, I was al-so a facil-ities engineer in
the Idaho Army Nationa1 Guard. fn that capacity, I
oversaw the design, construction, repair, and maintenance
of facilities and roads at Gowen Fie1d, the National25
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CASE NO. IPC-E-16_28
0s/0s/17
MORRISON, M. (Di) 2
STAEE
Guard's Orchard Training Range, and other National- Guard
facil-ities in Southern ]daho.
I began work at the Idaho Public Utilities
Commission in 20L4.
O. What is the purpose of your testimony?
A. I will discuss the costs and benefits of the
Company's proposed redundant line, and the
para11e1 line to facil-itate repairs on the
I will- also discuss the Company's proposed
Distribution base case, and its preferred
Underground Transmission route.
need for a
existing 1ine.
Overhead
alternative
I will conclude with a brief discussion of the
Company's analysis of proposed alternatives to a second
transmission l-ine, such as loca1 generation, electrj-cal
storage, and microgrids.
O. Please summarize your testimony.
A. Currently, the communities of Ketchum, Sun
VaJ-1ey, and Elkhorn (North Wood River VaIIey) are served
by a single 138 kV transmission Ilne originating at the
Company's Wood River Valley substation near Hailey, and
terminating at the Company's Ketchum substatj-on. The
Company is seeking a
Certiflcate of Public
Commission order granting a
Convenience and Necessity (CPCN) to
construct a second 138 kV transmission line connecting
the same two substations. The Company states that ao25
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CASE NO. IPC_E_16_28
05/0s/t]
MORRTSON, M. (Di) 3
STAFF
second, redundant
rel-iabl-e service
it is al-so needed
l-ine is necessary in order to provlde
and thatto the North Wood River Valley,
to facilitate reconstruction of the
138 kV transmission l-ine without j-nterrupting
to the North Wood River Va11ey.
existing
service
The questions
a second l-ine needed?
before the Commission are: 1) Is
2)
What costsnecessary? 3)
body of Idaho
The
evi-dence that
If so, what facilities are
shoul-d be borne by the general
Power rate payers?
Company has not provided compelling
the benefits of a fully redundant line
justify the $30 million dollar cost proposed for this
project. Nevertheless, a second line will be necessary
to facilitate repair of the existing transmission l-ine.
I will show that much of the cost of the
Company's preferred route would be j-ncurred providing
aesthetic benefits to the City of Ketchum. I do not
bel-ieve that it would be appropriate for the incremental
costs of providing these beneflts to be passed-on to the
general body of Idaho Power rate payers. Therefore, I
wil-l- recommend that the Commission direct the Company to
instal-1 a temporary Overhead Transmission Line as
necessary to facil-itate repair of the existing
transmission line. In the event that the Commission
determines that a second l-ine is needed, then I recommendt25
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CASE NO. IPC-E_16_28
05/05/1,1
MORRTSON, M. (Di) 4
STAFF
that an Overhead Transmission route through the City of
Ketchum be considered the base case. The City of Ketchum
and other affected cities/counties should be prepared to
in cost required todifferenceprovide the incremental
pJ-ace those facilities
Idaho Code S
whereby an
Improvement
i-ncremental-
transmi-ssion
underground.
50-2503 provides a mechanism
Idaho municipality may establish a Local-
District (LID) i-n order to pay for the
costs of undergrounding electrical
and distribution lines. Al-ternatively, the
Company may establish a surcharge for customers in the
areas benefitting from underground transmission and
distrlbution l-ines.
O. In its application, the Company stated that it
has been planning a second transmission l-j-ne in the North
Va11ey since 1913. Application at 6. What is the
historical background of transmission in the North Wood
River VaI1ey?
A. The existing Iine connecting the Wood River
Substation to the Ketchum substation is actually the
northern end of a 72 mil-e l-ine connecting the King
substation near Hagerman to
completed
the North Wood River Va1ley.
was in 7962This project
In 7973, construction of
at the Jim Bridger power plant was
(Exhibit 101).
the first 500 MW unit
behind schedul-e, andt25
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CASE NO. IPC-E-16_28
05/05/L]
MORRTSON, M. (Di) 5
STAFF
the Company was concerned that it might
suf f icj-ent generating
for summer 197 4. The
No. 272, which authorized
MW generating station near
Overhead Transmission l-ine
substation i-n Hailey to
for thisproposed route
in the present
Company's cost
(Exhibit 101 at
at the Company's request,
No . 27 2 . Order No . 261,07 .
O. What reasons did
resources to meet
Commissj-on granted
the Company to
the
Hailey, and a second 138 kV
connecting the Wood River
Ketchum substati-on. The
not have
projected demand
the Company CPCN
construct a 50
l-ine was similar to that
case (Exhibit 102). In the 1913
estimate for this second line was
2).
proposed
case, the
$385,000
In 1989, the Company completed a second line to
the Wood River Substation, and determined that a back-up
generator was no longer needed. It sold the generator in
1992 (Exhibit 103 at 2) .
The Company never constructed a second 138 kV
line from the Wood River substation to Ketchum. In 7995,
that the Commisslon
the Commission cancel-l-ed CPCN
the Company give for
remove its authority torequesting
construct a second 138 kV Vrlood Ri-ver-Ketchum transmissi-on
l-ine 1n 1995?
A. The Company gave two reasons:
performed an extensive reassessment and
l- ) The Company
concluded thatt25
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CASE NO. IPC_E_76-28
05/0s/1,7
MORRTSON, M. (Di) 6
STAFF
the line was not needed, either to meet projected foad
growth or to improve reliability. 2) The Company
indicated that it had considerabl-e difficulty obtaining
the necessary permits and rights-of-way for the project.
In particular, the Company indicated that there was
difficulty finding an aesthetically acceptable route
through downtown Ketchum (Exhibit 103 at 3 and 4) .
O. What has prompted the Company to seek a new
CPCN for a redundant Wood River-Ketchum l-ine?
A. In its response to Staff Production
ofa
Request No
redundantL6, the Company stated that its pursuj-t
transmission l-i-ne was prompted by " (1)
the 2001 Community Advisory Commi-ttee,
of the existing transmissj-on line which
replacement of a substantial portion of
(3) avoidance of construction and then
recommendation of
(2) increased age
requ j-res
the structures,
removal of a
temporary line
existing line,
by recent fire
to facilitate reconstruction of the
fire hazard as evidenced
O. How
and (4) increased
activity. "
was the Wood River Valley Community
in the Company'sAdvisory Committee (CAC) invol-ved
planning process?
A. The Company created a number of CACs throughout
j-ts servj-ce territory 1n order to obtain l-ocal guidance
1n identifying and planning j-mprovements and additions to25
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CASE NO. IPC_E_16_28
05 / 05 /17
MORRTSON, M. (Di) 1
STAFF
the Company's transmj-ssion and substation infrastructure.
On pages 7 and 8 of its application, the Company explai-ns
that it began creating CACs in response to Commission
guidance in the 2004 City of Eagle Case (Case No.
rPC-E-04-04).
Starting in 2007, the Company began seeking
formal input for its Wood Rj-ver VaIIey transmisslon
projects via the Wood River Valley CAC. The Wood River
Valley CAC assisted the Company's development of the Wood
Rj-ver El-ectrical Pl-an submitted as Company Exhibit No. 2.
The Wood River Val1ey CAC meeting minutes, the
Wood River Val1ey Electrical P1an, and related documents
indicate that the Company went to great lengths to make a
good faith effort to consider the needs and sensibil-ities
of communiti-es in the Wood River Valley in the
development of this pIan. Eurther, I should note that
the redundant Wood River-Ketchum line proposed in this
case is just one part of the overal1 Wood River VaIIey
Electrical Plan, and that there seems to be general
agreement by the Company and 1ocal communiti-es on most
other el-ements of the plan.
O. You state that there seems to be general
the p1an. Did theon most other elements ofagreement
CAC, or do
need for a
the communities in general,
redundant line in the North
agree with the
Wood River Va11eyo25
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and the Company's plan of service as described in the
Application?
A. On issues regardlng redundant service to the
North Wood River Va11ey, there is consi-derabl-e
disagreement, and many of the viewpoints expressed on
this particular topic are mutually excl-usive. Some
residents do not agree that any redundant service is
needed. Some residents agree that redundant service is
needed, but dj-sagree about the exact route chosen by the
Company. Some residents want the Company to consider
l-ocal- generation, el-ectrical storage, and microgrids in
lj-eu of a redundant transmission l-ine. Throughout the
CAC process, the Company supported community efforts to
explore each of these options. I wil-I discuss the
Company's analysis of these options l-ater in my
testimony.
A continuing point of disagreement was the need
and cost of undergrounding transmissj-on facil-ities in the
City of Ketchum. T will dj-scuss the costs of underground
transmission facil-ities l-ater in my testimony. Prior to
JuIy, 20L5 the Company had consistently reminded CAC
participants that local residents would need to pay for
the incremental costs of undergrounding (Application,
Exhibit No. 2, at 13). fn a July 6, 20L5 letter, the
Company announced its adoption of the much more expensive
CASE NO. ]PC_E-76_28
05/0s/11
MORRTSON, M. (Di) I
STAFF
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Overhead Distribution option as a base case (Exhibit
1,04), thus justifying a more costly underground
transmission option and greatly decreasing the need for
local- communities to fund the incremental- costs of
undergroundi-ng in the Ketchum area.
REDUIIDA}ICY AND RELIABILITY
O. What are the benefits and costs of a fuI1y
redundant l-ine in the North Wood River Va1ley?
A. A redundant l-ine is one method that the Company
can use to improve system reliability. In practice, both
the original and the redundant line would operate
simul-taneously, so that i-n the event that one line
experiences an outage, the remaining line would continue
servj-ng l-oad. Customers would see l-ittle or no
interruption in servj-ce.
Full redundancy comes at a high cost because it
requires the Company to fully dupJ-icate the existing
transmission line. Furthermore, the benefits of a
redundant line are only real-ized when the exj-sting line
is out-of-service. Since 1995, the Wood River-Ketchum
l-ine has experienced a total of 5 sustained unplanned
outages, with durations of between 5 and 126 minutes.
Had the Company's proposed second l-ine been in servj-ce
over that time peri-od, it would only have provided a very
small benefit for its $30 millj-on cost (Exhibit No. 105
CASE NO. IPC-E-16_28
0s / 05 /17
MORRTSON, M. (Di) 9
STAFF
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and Exhibit No. 106).
As stated by Company Witness AngelI (Angell
Direct at 2t), the existing Hailey to Ketchum 138 kV
transmissj-on has an unplanned sustained outage rate of
7.23 events per year per 100 miles. This compares
favorabl-y with Idaho Powerrs system-wide 138 kV
transmission average of 1.89 unplanned sustained outages
per year per 100 mil-es.
It is 1ikely that this excel-l-ent reliabillty
record j-s due, in large part, to the Company's pro-active
efforts to mitigate the risks of unplanned outages due to
fire, avalanche, weather, and other unplanned hazards.
0. Would a second line el-iminate al-I ri-sk of a
power outage in the North Wood River Valley?
A. No. Since 1995, the longest sustained outage
experienced by residents of the North Wood River Va1Iey
was a 700 minute interruption on December 24, 2009. The
Company explained that this outage was due to loss of
electrical supply when both transmj-ssion lines serving
the Wood River substation were out-of-service due to
incl-ement weather. In other words, both redundant lines
feeding the Wood River substation failed simul-taneously.
Because this incident occurred on lines feeding
the Wood River substation, the Company's proposed Wood
River-Ketchum line would not have mitigated the December
CASE NO. IPC-E-16_28
0s/05/71
MORRTSON, M. (Di) 10
STAEE
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24, 2009 outage. Further, as discussed above,
historically the existing Wood River-Ketchum fine has an
exceffent reliabj-1ity record. In short, a second Wood
River-Ketchum line is a very expensive means to achieve a
relatively small reliability improvement.
O. Did the Company submit a risk assessment of the
existlng line in this case?
A. Not in this case; however, 1t submitted a
comprehensive risk assessment in 1995 in support of its
request to withdraw its previous CPCN (No. 212). Key
portj-ons of this assessment were performed by external-
evaluators, including Energy Data Management, fnc. of
Col-orado, Power Engineers Inc. of Hailey, and Osmose,
Inc. of New York. Additional portions of the assessment
were performed by Idaho Power. The assessment concluded
that the risks posed by avalanches, fires, and other
unplanned events were Iow, and that the Companyr s
maj-ntenance and emergency management pJ-ans would be able
to quickly repair the damage caused by such events.
a. Have any key findings of the Company's risk
assessment changed since 1995?
A. The Company provlded no evidence that its
assessment of risks due to environmental- factors such as
aval-anche or fire had changed since its comprehensive
1995 survey, and so the need for a fuIly redundant line
CASE NO. ]PC-E-1.6_28
0s/05/11
MORRTSON, M. (Di) 11
STAEF
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CASE NO. IPC-E-I6_28
05 / 0s /t7
MORRTSON, M. (Di) L2
STAFF
does not appear to have changed sj-nce then.
Of course, the existing transmlssion l-ine is 22
years older than it was in 1995; however, the Company has
an aggressive preventive maintenance program in the North
Wood River VaIley. The Company regularly inspects the
l-ine, and schedules maintenance or replacement of damaged
poles and other equipment as necessary to preclude
potential hazards. Some portions of this l-ine have
already been replaced. As we wll-l- discuss Iater, there
will- eventually be a very real need for a temporary line
that could facilitate reconstruction of the existing
Iine; however, the costs of such a line are substantially
l-ess than the costs of a permanent, partially underground
Iine providlng full redundancy.
0. Is it correct to say that there is no need for
a fu1ly redundant l-ine in the North Wood River Val1ey?
A. Not at al-l. In the present case, the Company
bears the burden of proof to show that the benefits of a
second Wood River-Ketchum line justlfy a $30 mil-lion cost
that will be borne by fdaho Power's general body of rate
payers. I do not believe that the Company has met this
burden.
There are, however,
the Company did not explore.
1995 risk assessment assumed a
a number of hazards that
For example, the
50 year hazard.
Company I s
That is,I 25
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CASE NO. IPC_E-1,6-28
05/0s/71
MORRTSON, M. (Di) 13
STAEF
it analyzed
of occurring
evaluate the
catastrophic
earthquakes.
the line from
outages along this section
is littl-e justification for
hazards that have a 2Z or greater l-ikelihood
in any particular year. The Company did not
impacts of rare, but potentially
events such as sabotage, plane crashes, or
Such events have l-owa very
service
probability,
several days.forbut might remove
If such an event were to occur in mid-winter, the
consequences could be very severe for the residents of
the North Wood River Va11ey. The Company provided no
information indicating that it would not be able to
repair damage from such an evenL in a timely manner
(Exhibit 107).
RECONSTRUCTING THE EXISTING LINE
O. Why do you belleve that a second line will be
necessary to facil-itate reconstruction of the existing
line?
A. As I indicated earlier, the number of unplanned
of fine is quite 1ow, so there
a ful1y redundant fine.
Iine is nearing the end of itsNevertheless, the existing
useful operating lifer so
to rebuild it.
there will- eventually be a need
Along some portions of this line, woodpeckers
pose a substantial threat to the integrity of the
existing wood poIes, and the Company has already replacedt25
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CASE NO. IPC-E_16_28
05/0s/71
MORRISON, M. (Di) 74
STAEE
some woodpecker-damaged wooden pol-es with metal poles.
AngeII Direct at 27. When replacement is necessary, the
Company takes special care to minimize di-sruption to its
North Wood River VaI1ey customers: The schedul-ed outage
is advertised 1n l-ocal- media, preparatory work i-s done
ahead of time, needed materials are pre-positioned, and
three crews are used to move power l-ines from ol-d wooden
poles to new metal po1es. Notwithstanding the extra
effort, this work has typically required a schedul-ed
outage of nearly 8 hours per transfer. As the line ages,
we can expect the frequency of such outages to j-ncrease.
The Company estimates that 40 such planned
outages
Iine.
will be necessary to fully rebuild the existing
Ange11
What
The
Direct at 22.
is the useful life of
existing Iine traverses
winters and warm dry summers. These
conducive to fungal rots that afflict
in other parts of the country. Under
o
A
components of the line
the existing line?
a region with cold
conditions are not
wooden power poles
these condj-tions,
have a useful
was completed
are within
it is reasonable to expect wooden poles to
life of 10 or 80 years. The existing line
55 years d9o,
15 to 25 years
o. why
constructed to
so major
of the end of their useful lives.
is the cost of a temporary Iine,
facil-itat.e repair of the existing 1ine,t 25
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CASE NO. IPC-E_!6-28
05 / 05 /17
MORRTSON, M. (Di) 15
STAFF
less
abl-e
coul-d
peak.
Iine
loads
than the cost of a fuI1y redundant line?
A. The Company's proposed redundant line would be
to support a demand of 720 MW, so that the line
support the Company's current and projected winter
ft is likely that most repair work on the existing
would be performed during the summer, when peak
are much smalIer. The Historic Summer Peak Line
Application, Exhibit
a fuIIy
No. 2 at ?t
According to the Company, ful-l replacement of
the line conductor woul-d requi-re 6 to L2 weeks.
Application at L6. The Company considered instal-l-ing a
temporary line to facilitate replacement, but rejected it
because it "would almost assuredly be deemed a visual
impact by North Valley customers." The proposed
temporary line would "be placed in road right-of-wdy,
mostly along Highway 75, to minimize private property
impact and right-of-way costs. " Application at 16-11 .
Although I appreciate the Company's deference
to the aestheti-c sensitivities of its North Wood River
Loading for the
a temporary line
be much smaller
Va11ey customers,
and inconvenience
mil-lion permanent
North Wood River Va11ey is
constructed to facilltate
than redundant l-ine.
only 26 MW, so
repaj-rs could
I don't believe that the visual impact
of a temporary line justifies the $30
alternatives proposed by the Company.I 25
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CASE NO. ]PC-E-76_28
05/05/11
MORRTSON, M. (Di) 76
STAFF
THE COMPA}IYIS BASE CASE A}ID PREEERRED ROUTES
O. What is a base case system?
A. A base case
system needed to meet
base case system costs
system represents
a particular need.
are inc]uded in the
the minimum cost
Typically, only
Companyr s rate
base, and thus only base case
Company's rate payers. Costs
case costs should be borne by
be incurred.
costs wil-I be borne by the
incurred in excess of base
the parties causing them to
Because of their relatively l-ow cost, overhead
transmission systems are al-most always used to establish
the transmiss j-on system base case. The Commj-ss j-on
recogni-zed this in Commission Order No. 29634 (Case No.
IPC-E-O4-04) when it stated, "Aerial transmission l-ines
are the most cost-effective construction method and
represent 99% of all transmission lines in the nation. "
(Exhibit No. 108).
Municipal-ities that mandate underground
transmission or distribution l-ines are generally
responsible for paying the difference between the cost of
the underground system and the base case transmission
system. The Idaho State Legislature provided a means for
doing so via Idaho Code S 50-2503 (Underground Conversion
of Util-ities) when it conferred on counties and
municipal-ities the power to create Local ImprovementI25
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CASE NO. TPC_E_76_28
05/05/1'7
(Di) t]
STAFF
Districts (LIDs). This mechanism al-l-ows those who
benefit from undergrounding to pay for it without
burdening other ratepayers.
O. Briefly describe the four transmission routes
presented in the Company's application.
A. The Company describes four options: Overhead
Transmission, Underground Transmission, Overhead
Distribution, and Underground Distribution. A11 four
options
from the
Highway 75,
After that
option foll-ows
underground.
Both
options require
Ketchum on the
that is just south of Ketchum.
use the same common overhead transmissj-on pathway
Wood River substation in Hailey, along State
toa
point,four options diverge. The Overhead
point
the
Transmission option remains above ground until- reaching
the Ketchum substation. The Underground Transmission
essentj-al1y the same path, but does so
the Overhead and Underground Distribution
construction of a new substation south of
west side of Highway 75. From this point,
tie into the 12.5 kV distribution gridboth options would
in order to avoid a direct transmission route through
downtown Ketchum. The Underground Distribution option is
the most expensive of the four options, and I concur with
the Companyrs decision to rule it out as a viable option.
O. If the Commj-ssion were to accept the Company'st25
631 MORRTSON, M
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argument for a fu11y redundant line, whj-ch of these
options should the Commission adopt as a base case, and
what is its cost?
A. I recommend that the Commission adopt, ds its
base case, the Overhead Transmission l-ine route through
the Ketchum Downtown District, dS described on pages 18
and 1,9 of the Companyrs application.
The Company estimates that an Overhead
Transmission route through downtown Ketchum woul-d cost
$18.5 million (Exhibit No. 109). The Company cautions
that, unlike estimates for its proposed Overhead
Distribution and Underground Transmj-ssion routes, this
estimate does not incl-ude potential right-of-way costs.
For reference, the Company inc1uded $1,000,000 and
$600,000 in right-of-way costs, respectively, in its cost
estimates for its proposed Overhead Distribution and
Underground Transmission routes. Application, Exhibit
No. 7.
O. The Company concluded that the Overhead
Transmission option is not viable, and thus did not
choose it as the base case. Applicatj-on at 18-20; Angell
Direct at 29-31. Do you agree with the Company's
analysis regarding the viability of thi-s option?
A. I disagree with the Company's decision to
excfude Overhead Transmi-ssion as a base case option. As
CASE NO. IPC-E-16_28
05/05/1.7
MORRTSON, M. (Di) 1B
STAFE
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CASE NO. IPC-E-I6_28
0s/05/11
MORRTSON, M. (Di) 19
STAFF
I will discuss, the Company's proposed Overhead
Distributj-on base case would cost about $30 milllon, or
$11.5 million more than the cost of an Overhead
Transmission route. On page 19 of its application, the
Company discusses challenges to an Overhead Transmission
Ij-ne route through the Ketchum downtown district. These
challenges include the city's grid of streets, sidewalks,
and zero setback buildings. In its response to Staff
Production Request No. 14, the Company indicated that it
could instal-1 poles primarily in the public right-of-way
through downtown Ketchum by using ej-ther Triangular (TR)
or Tangent Angle (TA) configured poles in the downtown
Ketchum area (Exhibit No. 110). Using either of these
options, the Company could still need to obtain overhead
easements. The Company also indicated that it had
explored a Davit Arm structure that could avoid
transmission line overhead and cl-earance requ j-rements
The primary
1ts vi-sual-
Power does not
viable option for
through the downtown Ketchum district.
the Davit Arm structure is
The Company states, "Idaho
Davit Arm design would be a
transmission Iine route through the Downtown
District because the North Va11ey customers, in
parti-cu1ar Ketchum customers, would strongly oppose this
option based on its visual- impacts afone." (Exhibit No.
objection to
appearance.
believe the
the overhead
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CASE NO. IPC_E-16-28
05/05/71
MORRTSON, M. (Di) 20
STAEF
110).
In other words, the Company has explored
Overhead Transmission options that are technically
feasible, and that may not require easements. The
Company rejected these options because of l-ocal aesthetic
concerns.
The Idaho State legislature anticipated that
some communities might prefer undergrounding their
a mechanism for them to do so vi-autilities and provided
Idaho Code S 50-2503.
O. What is the Companyrs proposed base case?
A. The Company refers to its proposed base case as
the Overhead Distribution route. The Overhead
Distrj-bution route requires construction of a new
substation on the west sj-de of Highway'75 near Owl- Rock
road. Ange1l Direct at 21. This substation would
provide power to the existing distribution grids in
Ketchum and Elkhorn via five overhead distribution
circui-ts. The substation would receive power
State
from the
new common route transmisslon line along
cost of the
Highway
Overhead15. The Company estimates that the
Distributlon route woul-d be between $29.L and $31.1
mill-ion. Application at 22. The Company has rounded
this to $30 mil-l-ion.
O. Why do you believe this base case to bet25
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CASE NO. ]PC-E-76_28
0s / 05 /11
MORRTSON, M. (Di) 27
STAFF
inappropriate?
A. The Company's Overhead
considerably more expensive, and
Distribution route is
ir won't provide the
Transmission line.same benefit as a redundant Overhead
As stated in
conf i-gurati-on provides
the Company's applicati-on, this
only 60 MW of backup service for
the existing line's 120 MWGiven
a ful1y redundant el-ectrical-
2001 peak load of 63 MW, it
Distribution route woul-d be unab]e to meet the needs of
the North Wood Rj-ver ValIey.
In its application (at 22), the Company
existing customers.
rati-ng, the Overhead Distribution route does not provide
Companyr s
the Overhead
Company
to
path. Given the
is possibJ-e that
explains
decrease
decrease
that the Overhead Distribution route will not
River-Ketchum transmission
the frequency of
their duration.
events, but coul-d
event that the Wood
to fail, the
ties in order
outage
In the
line were
woul-d need to activate distribution
switch its power source from the Ketchum substation to
the new substation near Owl- Rock Road. To decrease
switching time, the Company proposes automated ties
control-l-ed f rom its dispatch center in Boise. Although
the Company has extensive experience using manually
controlled ties, fly understanding is that it has never
used remotely control-l-ed automated ties. The Companyt25
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CASE NO. IPC_E-16_28
0s/0s/71
MORRTSON, M. (Di) 22
STAFF
explained
outages,
Direct at
stiII experlence sustaj-ned
15. Given the existj-ng Wood River-Ketchum
transmission line's excell-ent reliability record, it is
difficult to see how the Overhead Distribution route
that customers might
even if switching were automated. Adelman
woul-d provide North Wood River Va1ley
noticeable reliability improvement.
The Company has stated that
Distribution option is consistent with
standard practice of providing redundant
servj-ce to an area; however, given that
residents any
the Overhead
the Company's
electrical
this option wil-l
not been usedrely on remotely automated ties, which have
by the Company, the al-ternative does not seem to
represent a standard Company practice.
The Overhead Distribution route woul-d permit
the Company to rebuild the existing transmissj-on line
without interrupting service to its North Wood River
Valley customers; howeverr ds discussed earlier, there
are much less expensive ways to accomplish this.
In short, the Company's proposed base case
appears to be an inadequate, non-standard al-ternative
used to justify the high cost of its preferred route.
O. What is the Company's preferred al-ternative
route?
A. The Company submj-tted three variants of an25
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CASE NO. IPC-E-I6_28
0s/05/17
MORRTSON, M. (Di) 23
STAFF
Underground Transmission route that differ only in the
point at which they transition from Overhead Transmission
to Underground Transmission. The transition point for
the Company's preferred route is near the j-ntersection of
Elkhorn Road and Highway 75 just before entering the City
of Ketchum ("TP1"). At an estimated cost of $30 million,
this is the l-east expensive of the three Underground
Transmission variants eval-uated by
The Company argues that
Overhead Distribution "base case'l
the Company
sr_nce its preferred
case, that the
Companyrs proposed
does not provide the
options, and so it
route is no more expensive than its base
Commission should approve its preferred Underground
Transmission route in a CPCN.
As I noted earfier, the
same l-evel- of redundancy as
should not be considered a
More importantly,
base case and its preferred
than the far more standard
other
base case.
both the Company's proposed
route cost $1f.5 million more
practice of using Overhead
Transmissi-on
A. What are some other problems with the
Underground Transmission option?
A. The Company's analysis did not compare the full
Iifecycle costs of Underground
however, the Company estimates
and Overhead Transmission;
the lifespan of an25
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Overhead Transmission line to be 10 to 80 years, whiJ-e
the Iifespans of underground transmj-ssion l-ines are
typically 30 to 40 years. Furthermore, although the
Company did not provide replacement cost estimates for
either option, the replacement costs of underground
transmission lines are expected to be substantially
higher than the replacement costs of overhead
transmission Lines. In short, the Underground
Transmission option would last hal-f as long and cost much
more to replace than the Overhead Transmission option.
Of course, these costs woul-d eventual-1y become part of
rate base and be borne by Idaho Power's general body of
rate payers (Exhibit No. 111).
Eurthermore, in its response to Staff
Production Request No. 6, the Company estimates that
annual operations and maintenance (O & M) costs for its
Underground Transmission option wou1d be twice that of a
comparable Overhead Transmission option ($26,558 vs.
$1-3,724) . Again, these j-ncremental costs woul-d be passed
on to Idaho Powerrs general body of rate payers (Exhibit
No. 111).
Of considerabl-e concern is the Company's l-ack
of experience repa j-ring underground transmission l-ines.
In the event that major repairs are needed, the Company
has stated that it would use qualified contractors to
CASE NO. IPC_E_16_28
05/05/Ll
MORRTSON, M. (Di) 24
STAFF
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CASE NO. ]PC-E-1,6_28
0s/05/17
MORRTSON, M. (Di) 25
STAFF
ef f ect repairs,'
maintain a list
own research, I
contractors in Idaho or in the Pacific Northwest. Based
on my research, it appears that the nearest contractors
capable of making major repairs are in Los Angeles and
Chicago (Exhlbit No. ll2).
LOCAL GENERATION A}ID DISTRIBUTION OPTIONS
0. What other redundancy optj-ons were evaluated?
A. Starting in 2001, the Company began seeking
formal input for its Wood Ri-ver Va11ey transmission
projects vi-a the Wood River Va11ey Community Advisory
Committee (CAC). CAC members requested that the Company
eval-uate various l-ocal generation and storage options as
al-ternatives to a redundant 1ine. These options included
diesel- generation, gas turbine generation, biomass
generation, sol-ar generation, and battery back-up. The
Company determined that the costs of each of these
options exceeded the costs of the Company's proposed
transmisslon line. I concur with the Company's
assessment. Furthermore, as f noted earl-ier, there is no
compelJ-i-ng case for redundancy.
COI{CLUSIONS AIID RECOMMENDATIONS
O. Please summarize your conclusions and
recommendations .
however, the Company does
of qualified contractors.
determined that. there are
not currently
Based on my
no such
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A. The Company is proposing a project that would
add $30 million to its rate base, and this cost would
eventually be borne by the general body of fdaho Power
customers in the form of increased rates. When
contemplating such projects, the burden is on the Company
to show that its proposa1 is necessary, and that it
represents the least expensive means for providing
reliable electric power to its customers.
The residents of the North Wood River Va11ey
already benefit from very reliable power, and the Company
provided no evidence that in the event of a rare
catastrophic event, it would be unab1e to restore power
in a timely manner. fn short, the Company has not
demonstrated that a second Wood Ri-ver-Ketchum l-ine would
provide a significant rel-iab1l-ity benefit to the North
Wood River Va11ey.
As I mentioned earlier, the Company has
instituted a proactj-ve preventive maintenance program, so
most of the po1es, transformers, and conductors of the
existing Wood River-Ketchum transmission l-ine are in
exceffent condition. Nevertheless, the line is nearing
its 55th year, and we should anticipate that it will be
necessary to renovate the l-ine in a few years. In order
to preclude numerous prolonged outages during renovation,
T recommend that the Commission direct the Company to
CASE NO. IPC_E_76_28
0s/05/71
MORRTSON, M. (Di) 26
STAFF
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CASE NO. ]PC-E-16_28
05/05/1,1
MORRTSON, M. (Di) 21
STAFF
instal-1 a temporary Overhead Transmission Line as
necessary to
transmi-ssion
If
transmission
facil-itate repair of the existing
l-ine.
the Commission determines that a second
line is necessary, then f recommend that the
the Company to consider the OverheadCommission order
Transmissj-on route through downtown Ketchum as the base
case for determining the cost to be borne by the
Company's general body of rate payers, and that any
additional- costs of undergrounding be funded locaIIy.
O. Does that conclude your testimony?
A. Yes, it does.
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CSB REPORTING
(208 ) 890-s198
MORRTSON (X)
Staff
(The following proceedings were had in
open hearing. )
MS. HUANG: The witness is avail-abl-e for
CTOSS.
COMMISSIONER ANDERSON: Thank you. Idaho
Power.
MR. WALKER: Thank you, Mr. Chairman.
CROSS_EXAMINATION
BY MR. WALKER:
O Good afternoon, Mr. Morrison.
A Good afternoon.
O Now, on page 3 of your direct testimony,
l-ines 1-0 through L4, you state, "The Company has not
provided compelling evidence that the benefits of a fully
redundant line justify the $30 million cost proposed for
this project.r' What did you mean by the standard of
compellj-ng evidence?
A The Company provided in 1995 evidence for
withdrawing its applicati-on, its CPCN back in 1995, and
that evidence was convincing to the Commissioners at that
time, and the Commission accepted their proposal to
withdraw the applj-cation. The Company provided no
similar application stating that there had been any sortI25
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CSB REPORTING
(208 ) 890-s198
MORRTSON (X)
Staff
of change other than an increase in the age of the l-ine
since then;thus,
back
they didnrt meet the same standard that
9, you
burden
state, When
is on the Company to show that
necessary, and that it represents the
they had met
O
o
in 1995.
is that on page
contemplating such
have you
rebuttal-
26, l-ines 4 through
projects, the
its proposal is
least expensive
Is that themeans for providing
same burden of proof
were referencing on
And
Yes,
And
-n.
re1iable electric power.
or standard of evi-dence
page 3?
it is.
that you
reviewed Mr. Ange11's direct
testimony and his testimony?
A Yes, I have.
O Have you revj-ewed those sections,
particularly Mr. Ange11's rebuttal- testimony on pages 3
through 6, where he generally describes how Idaho Power's
system is designed, configured, planned, constructed, and
operated?
A Yes, I have.
O And do you agree that the concept, the
concepts of spreading risk across muJ-tip1e facil-ities
instead of relying on a single facility, do you believe
that to be a prudent practice for a utility when planning
and designing its system?t 25
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CSB REPORTING(208) 890-5198
MORRTSON (X)
Staff
A ft's one practice
utility's tool kit.
0 And similarly, do
prudent practice
standards around
secondary sources
AI
Ofn your direct
it correct15 through
need for a
Va11ey? "
that can be in the
for a utility to
you believe it's a
plan for and have
eliminating radj-a1 service and providing
of energy to customers?
do.
there?
A
o
again talks
million cost
A
o
7J, rtrs
fu1ly redundant l-ine in the North Wood River
"Answer: Not at a11." Do you see that
Yes, yes.
And then the remai-nder of that paragraph
a $30about burden of proof
with reference to the
Yes, that's what I
And you don't mean
testimony on page 72, llnes
to say that there is no
and menti-ons
lower cost that in your mind that
potenti-aI benef its.
say.
to say that at some
this line wou]d then be
j ustified?
A It could be justifj-ed at a lower cost,
depending on how l-ow.
O So how do you consider in that equation
the prudency of the way the Company plans and designs itsI25
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CSB REPORTING
(208 ) 890-s198
MORRISON (X)
Staff
system to where l-oads in excess of 40 megawatts initiate
a second source of generatj-on in that substation?
A WeI1, I think that the 4O-megawatt
standard described by the Company and, in fact, the
description by the Company is that it is actually a load
planning standard and not rea11y a reliability standard,
I woul-d direct you back to Mr. Ange11's testimony where
he described, for example, what Rocky Mountain Power does
and they actually go through and do a full risk
assessment, and I believe that a risk assessment is
appropriate and not
which there i-sn't a
O Ifwe
a standard based on l-oad growth,
go
of load growth up there.
to the next page on page 13,
state, "The Company provided no
that it would not be avai-Iab1e to
an event." Do you see that
l-ot
lines 9 through !2, you
information indicating
repair damage from such
there?
A Yes, I do.
0 And if you recal-l, thj-s is part of the
same answer where it started off with a questi-on about
whether it was correct to say that there was no need for
a redundant line, and you started that answer with, "No,
not at aIlr " and conclude with, "The Company provided no
information indicating that it would not be abl-e to
repair damage from such an event. " You seem toI25
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CSB REPORTING
(208 ) 890-s198
MORRTSON (X)
Staff
large of a load and
be impacted by such
catastrophic events
out of service?
on a radial servi-ce could
weather or other
acknowledge in between there, do you not, that
elj-mination of the risk assocj-ated wj-th serving that
population
things as
that would possibly take that radial
A WeII, I don't bel-ieve I tied that to the
size of the 1oad, did T?
O No, but you did at least acknowledge that
that's a val-id concern, do you not?
A Wel-l-, the posltion of
was that if
Staff, and, of
the Company is going
needs to meet a
course, I took on this,
to come in and ask for rate base that it
pretty high burden of proof before putting that burden on
the rest of the ratepayers. This isnrt necessarily the
same as saying that there is no possibility and no risk
that something could go wrong, but the only information
that we have, the only formal studj-es that we have from
the Company were the 1995 study saying there rea11y isn't
any risk, and the Commission shoul-d al-l-ow the Company to
withdraw its CPCN, So I'm not stating that there is no
risk. f'm statlng that the Company provided insufficient
evidence of such a risk. In fact, I don't think they
provided
other low
any evidence of sabotage or meteorites or any
risk but high impact events.t 25
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CSB REPORTING
(208 ) 890-s198
MORRTSON (X)
Staff
O Do you have Mr. Ange11's testimony with
you?
A I can find it. Yeah, I have it here.
O Coul-d you please go to Mr. Angell's direct
testimony, page 3, line 22?
A Okay.
a On line 22, Mr. Ange1l's testj-mony states,
"Access to repair the line is impeded by residentj-al
development, rough terrain, and aged construction roads
in many areas. The mountainous terraj-n limits vehicfe
access, impedes equipment set-up and contributes to
ava.l-anche threats. This l-ine's access Iimitations may
result in extended outages for line conductor, insulator,
or structure failures caused by, among other things,
vandalism, inclement weather, wood decay, woodpecker
damage, avalanche, fire, and microburst wind events
(col-lectively 'Line Events'). Power outages caused by
avalanche, flre, and other natural events afso negativeJ-y
impact the emergency and life safety response activities
that are critical during these events"; so is it rea1Iy
true that the Company provided no information like you
say about the possibility of these events happening?
A Those are the same events and the same
things that they studied in 1995.
O Is it necessary to do to spend a lot of25
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CSB REPORTING(208) 890-s198
MORRTSON (X)
Staff
money and do independent analyses and studies to
recognize that any of these things could be a possible
threat that coul-d take out a radial line?
A WelI, they did that in 1995.
O And is there any real compelling reason
that we can't use our common sense to real-ize that those
are possible threats to a single l-ine, especially when
the stakes are greater wlth load over 40 megawatts and
population over 9,000 customers?
A We1I, I don't know that you won't find
that in 1995 the load wasn't over 40 megawatts.
O And do you know, sir, back in '95 when the
Company asked to have the previous certificate of public
convenience and necessity revoked, did the Company -- was
that a complete walk-away by the Company of the North
ValJ-ey and issues re1ated to the redundant l-ine? Was
that a done deal?
A Welf, they brought in some expert
witnesses and they brought in studj-es and they asked the
Commissioners to revoke the CPCN and the Commissioners
did. Whether that is a
certaj-nly did not
trying to put that
0 And
documents from '95
complete walk-away or
like they intended tosound
not, they
continue
in.
you reviewed some of those case
and actually attached some ast25
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MORRTSON (X)
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exhibits; correct?
A There's some, yes.
O Do you recall anything in those documents
from the '95 case about the Company making a commitment
to l-ook at that situation again in 10 years?
A I do not.
O Woul-d it surprise you if there were
commitments made by the Company to not completely walk
away from those customers and to continue to pursue those
concerns in the future?
A WeII, I don't believe Idaho Power would
ever walk away from its customers.
O So is it rea1Iy reasonabl-e to expect that
after the '95 case that we would never revisit the issue
of providing a redundant source of energy to the North
Wood River Va11ey?
A Please restate the question.
O I said is it reasonable to think that
after the '95 case, the Company would never revisit
issues rel-ated to providing redundant service and
eliminating the radia1 feed to the North Wood River
Va11ey?
A I think it woul-d be reasonabl-e to do that.
I al-so think that they need to bring in the same kind of
wasn't needed back inproof that they did to say itt25
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O So for
even you recognized in
probabllity
A Yes.
O type
A Yeah.
O But
radial feed serving
these kinds of major threats that
your testimony, these would be low
things ?
very high consequence if we have a
over 9r 000 customers?
A I concur.
And with such low probability, hiqh
do you
u
consequence
spend a lot
us -- what
A
you that
events,
of money
wou]d we
really think itrs
detail-ed studies
necessary to
to giveand do
gain
ir
from that?
could have convinced me that
a need for a redundant line. There
We11,
there was
wou]d be evidence to show that there was need for a
redundant line.
I
by compelling
than the mere
So I'm trying to figure out
evidence and burden of proof
fact that these
what you mean
and what more
you believe we were required
possibilities exist that
to bring in here and show?
A WelI, those same possibiJ-ities exist
almost everywhere in the system, you know, Garden City,
Meridian. They exj-st just about everywhere in the
CSB REPORTING
(208 ) 890-s198
MORRISON (X)
Staff
system, so I would be interested to know why this
particular area, the North Vrlood River Va11ey, was
recej-vlng special treatment and getting a special study.
O So you are correct they do exist
everywhere in the system and what do you think a prudent
way to address these things that exist everywhere in our
system would be? Would it be perhaps to have a planning
and design standard that looked at metrics such as load
service out of a substation to det.ermi-ne when we would
make decisions to eliminate radials? Maybe when we cross
that threshol-d to where the conseguences of losing that
radial for that load become too great and we need a
second source, would that be a reasonable way to deal-
with these things that exj-st everywhere?
A You said a standard that the Company has?
O Uh-huh.
A We asked the Company if they had a written
standard and they said that it was not written down
anywhere. It was in one of our productj-on requests.
O You are aware that Mr. Angell testified
that the Company has a standard of that once a
distribution substation reaches 40 megawatts?
A His response to production I don't
remember the production request, but it al-so stated that
it wasn't written down anywhere.
CSB REPORTING
(208 ) 890-s198
MORRTSON (X)
Staff
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O Okay, but you're willing to accept that
that's a standard that the Company uses as Mr
testified to pIan, design,
operate its entire system?
A That sounds
p1an, and construct
like thatrs what they do,
yeah, so I guess that's a standard.
o
proceeding,
A
O
testimony?
A
Okay, and testimony is evidence in this
Do you not accept Mr. Ange11's
woul-d be a reasonable
deal with these types
exj-st everywhere?
A When you say "these
are we talking about?
O These types of l-ow
consequence events that we've
A We1I, I think
Ange11 has
and
types, " what things
probabillty, high
been discussing.
thatrs one thing that could
other ways to mitj-gate those
risk is just simply too low
is it not?
Yeah.
does to design
o
oh,
for
And
I accept that that's what the Company
l-oad.
SO do you think do you think that
approach for a utility to take to
of things that, like you said,
be considered, but there
risks and it may be that
probability to mitigate
are
the
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0 Have you reviewed Mr. Porterrs prefiled
rebuttal- testimony?
A Yes, I have.
O Do you have that with you, sir?
A Yeah, 1et me get it out.
0 Could you go to I'd like to refer you,
please, to page 5 and 6 of Mr. Porter's rebuttal-.
A Sure.
O There's a photograph on page 6 and in thi_s
section of testimony, Mr. Porter is describing an event
that occurred in Jackson Hol-e, Wyoming, in February, I
believe.
A Uh-huh.
O And isn't it true that this particular
line Jackson Hol-e is a somewhat similar mountai-n
resort, ski resort, community that we're dealing with
here?
A Just like existed in 1995.
O And this particular event with the line
right next to the highway took approximately five days to
remedy?
A Uh-huh, that's what he said, yeah.
0 So are you telling us today that we're
required to wait in this instance until some disaster
such as this at Jackson Hole happens before we're
659CSB REPORTING
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MORRTSON (X)
Staff
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MORRISON (X)
Staff
required to
community or
according to
designed to
system?
A
saying that
probability
possible.
A
1995 study.
O
the construction of
No, Irm not sayJ-ng that at all.
the Company did not provj-de in its
take action to remove a radial feed for this
is it reasonabl-e to upgrade service now
the design reliabillty standards that are
decentral-ize and minimize such risk on our
evidence that was necessary in order for us to
whether we can make a head-to-head comparison
actually in
rebuttal,
something like this. That was not
original application, it was in the
certainly agree that there's a possibility that the
Company did not provide sufficient information to
Itm
filing the
evaluate
of
their
but I
evaluate these things and
the Company would l-ike to
money that it ought to do
0
additional
I guess that's
spend $30
a littl-e
mil1i-on
I believe if
of ratepayer
more homework.
Well-, I'm just trying to sort out what
information we'd be required to show about the
of these events other than that they're
Show me why we shou1d no longer accept the
Was the 1995 study, was that done seeking
a redundant line?
A It was done to el-j-minate or request thatI25
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CSB REPORTING
(208 ) 890-s198
MORRTSON (X)
Staff
the Commission revoke a CPCN requiring the Company to
construct a redundant line.
a So those studies in that case was for a
different purpose than what werre here for today; is that
not correct?
A I guess you could say that. That seems
very thin to me.
O So if the issue in our case is whether
it's reasonabl-e based upon the Company's standards of
exceeding 40 megawatts and popu1ation of customers that
exceed 9,000 to el-iminate a radi-al feed, to eliminate the
risk of catastrophic consequences that may happen if that
radial- feed is disrupted, regardless of how well the
current existing radial feed performs, do you think that
question is exactly the same as to whether that community
shoul-d continue to exist on that radial- feed?
A We1l, certaj-nfy, in 1995 the system was
either at or near 40 megawattsr so I would ask why that
particular criteria was not appJ-i-ed back then.
O So isnrt it true, sir, that al-l the issues
about how wel-1 or not the existing line performs is only
rea11y rel-evant if that community remai-ns subjected to
only that single
A]
line?
don't understand the questi-on.
O Does it make a dj-fference how wel-l ort25
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CSB REPORTING(208) 890-5198
MORRTSON (X)
Staff
poorly the exlsting line performs for this Commj-ssion to
make a deci-sion about whether Idaho Power's obligation to
radial by areliably serve
redundant feed?
A
requires elimination of that
How poorly or wel-l it
when it comes to reliability, I think
definitely should take into account that
performed extremely we11.
O So if one of the concerns
performs.
that the
that
I guess
Commi-ssion
l-ine has
if the main
concern that we're trying to address is one of these
possible catastrophic events, is 1t rea11y relevant how
well or poorly that l-ine performs on a day-to-day basis?
That's not real-1y the risk we're looking at, is it?
A We11, I think risk has two components.
There's probability and the other is impact, and in this
particular case, I think fol-ks have tal-ked about
resilience. The ability of the Company to recover and be
able to go repai-r that line quickly woul-d be resilience,
and the Company provided no informatlon that would lead
anybody to bel-ieve it would take them longer than 24
hours to repair to recover from one of these impacts.
Now, I think certainly think that if the Company took a
lot longer than that, that would be rel-evant. That would
be somethi-ng the Commission would want to know.
O So there is testimony, is there not, thato25
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CSB REPORTING(208) 890-s198
MORRTSON (X)
Staff
coul-d take days
been down? Do
if the l-ine were to go down j-n one of the mountainous
stretches of the existing l-ine durlng the winter that it
to even get access to where that line has
reca}l that?you
Ido not. There' s an awful l-ot of
testimony therer so if you coul-d direct me to
O You wou1d accept, subject to check, that
that's contained 1n Idaho Power's testimony or do we need
to find it?
A f f you cou1d find it, I'd appreciate it.
O I 'm stil-l- j-n Mr. Porter' s rebutta1
testi-mony.
A Okay.
O Do you see page 5 -- we actually already
were on the right page, I apologize for that.
A Sure.
0 Page 5 of Mr. Porterrs rebuttal- testi-mony,
l-ines 76 through 2!, "If the line were to fail in one of
these difficult access areas during the winter, it could
take several days or weeks to restore electric servi-ce,
jeopardlzing public safety, essential services,
businesses, and increasing the potential for extensive
property damage. It is not a question of if, but when
some event (ice loading, avalanche, high wlnds, fire,
etc. ) will take the line out of service and the Northo25
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CSB REPORTING
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MORRTSON (X)
Staff
VaJ-Iey
that I s
isn't
will- be without
rea11y the risk
it?
A Yeah, it
power for multiple
that we're talking
days " ,' so
about here,
this is part of rebuttal,
submitted my testimony.
0 And you didn't have the
prior to filing your testimony?
A I did not.
O f'm back on your direct
and I would point out that
which was fil-ed after I had
advantage of that
l-s
testimony now,
bottom of page B,sorry, on page B, page B to 9,
really starting on fine 20 and
9 through l-ine 5, just before
A Yes.
at the
reaIIy going over to page
your next heading
O you're talking about prior to July
2015, the Company had consistently reminded CAC
participants that l-ocal residents would need to pay for
the j-ncremental costs of undergrounding. fn a July 6,
2075, letter, the Company announced its adoption of the
much more expensive overhead distribution option as a
base case, thus justlfying a more costly underground
transmission option and greatly decreasing the need for
l-ocal- communities to fund the incremental- costs of
undergrounding in the Ketchum area. Do you see that
passage?o 25
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CSB REPORTTNG(208) B9o-s198
MORRTSON (X)
Staff
A Yes.
O And you cite to your Exhibit 104 in that
passage;that correct?
Yes,that was the letter provided through
by the Company.
is
A
production request
O And implication with that passage is
constructed this new base option
underground option; is that what
to justify a more
what you cite; correct?
we look at who is this letter
your
that somehow the Company
costlyto justify a
you're saying
A
more
option
this is
Yes.
So if
recognize thj-s Exhibit 704?
there ?
V[e11, it seems like that to me.
MR. WALKER: May I approach?
COMMISSIONER ANDERSON: You may.
(Mr. Wal-ker distributing documents. )
BY MR. WALKER: This is Exhibit 104 from
sir. Do you have that there?
Yes, f do.
So this is the l-etter you cite and do you
It f s a two-page l-etter.
O
your testimony,
A
u
A Yes.
July
with some new
O This is the letter you referred to, the
6 l-etter, ds evidence of where the Company came up
costly
underground,
A
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addressed to, Mr. Morrison? Is it addressed to members
of the community advisory committee?
A That's what it says, "Dear Wood River CAC
Member. "
O And itrs from Mr. Angel1?
A Yes.
O And is it fair to say he's informing the
community advisory committee of the current status?
A It says itr s a l-ine update.
O ft's an update, so bullet point No. 1 --
wel-l, before we get to the bull-et points, it says here
that the project see in the middl-e there after the
parenthetj-cal (the project), it says, "The project is the
same as the CAC's initial- recommendation in the Wood
River Electrical Plan" i do you see that there?
A Which bull-et is that?
O Thls is in the opening paragraph.
A Okay.
a So to paraphrase that opening paragraph,
Mr. Morrison, Mr. Angel1 is essentially telling the CAC,
h"y, we've done some analysis on these l-ines and we have
some updates about that analysis; rlght?
A Uh-huh.
O And the last sentence j-n that opening
paragraph, "An additional- outcome of this assessment is a
CSB REPORTING
QAg) 8 90-s198
MORRISON (X)
Staff
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CSB REPORTING(208) 890-s198
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significant overall cost reduction to the community for
the net expense of the underground transmission portion
of the pro j ect. I'
A Yes, that's correct.
O Is that the sentence that 1ed you to
accuse the Company of creating a new base case to justify
a more expensi-ve underground option as you state in your
testimony?
A We1l, I don't know about accusing the
Company,
entirety
had been
the folks
but that is that and the l-etter taken in its
led me to believe that at one point the Company
had consistently told
pay for
consistent the Company
that they would need to
undergrounding.
A And you say that you said on page B to
9 that in a July 6 l-etter, the Company announced its
adoption of a much more expensive overhead distribution
option as a base case. Can you point
A Just a second. Where are we again?
O That's this passage from your testimony
that we've been looking at at the bottom of page 8 to the
top of page 9.
A Okay, yes.
O So can you show me in this letter here
where it is that, ds you said it, the Company announcedI25
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MORRTSON (X)
Staff
its adoption
distribution
more costly
A
not the way
v
Ietter?
A
openj-ng paragraph of your letter in
it says, "The fol-l-owing changes l-ed
a semicolon, colon. I'm not
of a much more expensive overhead
optlon as a base case, thus justifying a
underground option?
No, they didn't state it that way. Thatrs
it's stated.
So that's your interpretation of this
Yes, it is.
O And after the very l-ast sentence in the
A
o
A
Now, where is this again?
This is in your Exhibit No.
Yeah, there's two pages of
Exhibit No. 4 [sic],
to this resul-t" with
L04, sir.
an exhibit,
where is it?
0 So the following
result and then there's a number
changes l-ed to this
of bullet points that
finish out and go over on to page 2.
A So if you l-ook down to the second the
bottom bull-et point
O WeIl,
A WeII,
bel-ieve that this is
"The substation and
l-et's start with
you've asked me
an announcement
bullet point No. 1
what led me to
of the distribution.
overhead distribution method shoul-dt25
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MORRTSON (X)
Staff
be used as the reference base case when determining the
incremental cost to be funded by the local- community,
which requj-res underground facilities. "
O Okay.
A That's what 1ed me to bel-ieve that they
were using the underground base case as an option.
O Yes, but what led you to believe that this
was something that the Company came up with trying to
justify a more costly underground transmission option?
These bul-l-et points don't talk simply about the one
construction overhead -- substation and overhead
distribution construction method you referred to, do
they?
WeI1, I
witnesses,
think if you read the testimony of
the Company they talk about the overhead
distribution, state that it ought to be a base case and
then tel1 you all the reasons that it's not going to
work. They start off by telling you that it only
provj-des 50 megawatts of power. fn 2001, the peak was 63
megawatts. They go through and they tel-l- you that in the
event of certain kinds of power outages that the system
wouldn't be able to react very quickly to it, and they
indicate in their testimony, al-so, that if there were any
kind of l-oad growth up there, they would need to change
and that this particular method, the overhead
A
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MORRTSON (X)
Staff
distribution, woul-d not be capable of meetlng any kind of
increase in load without changing and adding expense to
the option, so that l-ed me to believe that this is not
real-ly a base case. It does not actually meet the peak
load.
O Would it eliminate the radial- service?
A If it can't meet peak load, it can't
eliminate the radial service. It shoufd not have been
used as a base case. It is not adequate to meet the load
that, for example, the Company's underground transmission
option or the fess expensive overhead transmission option
would be able to provide. It's nowhere near that same
amount of load and it does not meet the peak l-oad that
the Company has stated that they experienced back j-n
2007, so it's not a base case.
(Pause in proceedings. )
O BY MR. WALKER: So Mr. Morrison
A Yes.
O you also address
selection of overhead transmission
Ketchum as an appropriate
A I think as
base; is
in your testimony a
through downtown
that correct?
an appropriate base case,
yes.
O And on the top of page 20, you sdy, "fn
other words, the Company has explored overheadI25
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CSB REPORTING(208) 890-s198
MORRTSON (X)
Staff
transmissj-on options that are technically feasible, and
that may not require easements. The Company rejected
these options because of l-ocal- aesthetic concerns. " Do
you see that there?
A Yes.
O And you stated earlier that you only
provided direct testimony; correct?
A Yes, that is correct.
0 You didn't have a chance to weigh in with
anything after the filing of rebuttal or surrebuttal-?
A No, I did not.
O And did you review that?
A Yes, I did.
O And did you review the information about
viability of the overhead transmission through
downtown?
A Yes, I did.
O And that apparently doesn't change any of
your recommendations or analysis?
A No, there really wasnrt any -- there was a
l-ot of subjective opinion like we've heard expressed here
about what the possible costs might be, but we didn't get
any actual costs or anything even committing to a range
of costs.
O And you say at the top of page 20 that theI25
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CSB REPORTING(208) 890-s198
MORRISON (X)
Staff
Company rejected these options because of local aesthetic
concerns?
A Yes, I did.
O Does it say anywhere in
that that was the sole and only reason
rej ected?
A No, they enumerate a number of reasons,
but that certainly tops the list.
O So in your mind, that's the number one
reason that the Company did that?
A That is what came across to me from the
testimony that was in a production request.
0 Does that stil-l- leave you with that same
impression after rebuttal and surrebuttal as wel-1?
A Yes, it does.
O And in your experience and background,
have you ever been employed as a transmission planning
engineer or been employed by a utility or anywhere el-se
where you had to design systems?
A No.
O Have you ever been invol-ved in the
construction of overhead transmission lines?
A At a manufacturing plant, yes.
O Okay, and just preceding that statement
the top of page 20, your direct testimony, pages 19 and
the Company's case
that that was
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20, you tal-k about Davit Arm structures on line 79, page
19. You af so tal-k about
A Which page are you on again? 20?
0 Page 19.
A Page !9,
O You also
Angle configured poles.
l-ine 10 to L2.
A Yes.
O And most
Triangular or Tangent
page 10 or page 79,
okay.
talk about
That's at
from a discovery response
that construction through
A Yes.
Uh-huh.
So it's
the Company provided saying
it with your concl-usion that
that j-nformation you obtained
from the Company talking about
downtown Ketchum; right?
that it's not viable to build
it is viable to build it?
of
O You referred to Exhibit 110?
and experience relying
your opinion with your background
on the very same information that
A
a
A WelI, T think one of the things that f'm
getting across here is, for example, I was attempting to
show the lengths to whi-ch the Company was going to
attempt to make this attractive, you know, aesthetically
appealing, and that goes to one of the questions you
asked me a l-ittle bit d9o, but at the same time that in
CSB REPORTTNG(208) 890-s198
MORRISON (X)
Staff
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CSB REPORTING(208) 890-s198
MORRTSON (X)
Staff
fact these options are viable. They may not be
aesthetically appealing, but technically, they're viable
and that's what I've stated j-n my testimony. Theyrre
technj-calIy viable. They may not be aesthetically
appealing.
O Do you recognize any difference between
somethj-ng thatrs technlcally possible or something that's
practically feasible?
A Yes.
MR. WALKER: I have no further questions.
COMMISSIONER ANDERSON: Thank you, Mr.
Walker. We'11 go through the intervenor list. Rolling
Rock, Mr. Adams.
MR. ADAMS: No questions.
COMMISSIONER ANDERSON: Kiki Tidwel1, Mr.
Richardson.
MR. RICHARDSON: No questions,
Mr. Chairman.
COMMISSIONER ANDERSON: Si-erra Club, Ms
Nunez.
MS. NUNEZ: No quest j-ons.
COMMISSIONER ANDERSON: CoxCom,
Mr. Arkoosh.
MR. ARKOOSH: No questions.
COMMISSTONER ANDERSON: City
Thank you
of Ketchum.I 25
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CSB REPORT]NG
(208 ) 890-s198
MORRISON (Com)
Staft
MR. JOHNSON: No rookie questions.
COMMISSIONER ANDERSON: From one rookie to
another. ft's a good thing I'm not
any Commission questlons? Yes.
COMMISSIONER RAPER:
questions. I think that was aimed
yes.
that I
high.
sensitive. Are there
have a couple of
rner and my mother's
heart. Welcome to
I
dL
response in me wants to say bless your
our Commissj-on. You're welcome back any time.
EXAM]NATION
BY COMMISSIONER RAPER:
0 Dr. Morrison, try to forget about I
mean, with respect to the dialogue you were having with
Mr. Wa.l-ker, but try and forget the particul-ars of this
case, do you think that redundancy, generally speaking,
provides resiliency?
A It can provide incremental resiliency,
As an engineer, f would like all the redundancy
can get, but the costs of that are extremely
O So you don't di-spute the conversations
earl-ier in the day with other wi-tnesses, some combination
of Idaho Power witnesses, who were talking about NERC
standards and those types of things as far as your issuet25
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CSB REPORTING(208) 890-s198
MORRISON (Com)
Staff
is not the proximitlz of the lines to one another?
A No, not at all.
O Okay; so then you made a statement when
you and Mr. Walker were first chatting about sometimes
there's too low of a probability to mitigate. I'm
wondering how that comports with Idaho Powerts obligation
to serve and provJ-de reliable service.
A Well, there' s extremel-y rare events, do
asteroid impact, alien invasion. You know, there's some
probability that these things could happen, but we do not
in general attempt to protect or try to mitigate them,
because either they're very 1ow probability and, also, we
probably don't know how to mitigate against an alien
invasion. I mean, I wouldn't, so I guess, you know,
there are some things that are just so l-ow that we
woul-dn't attempt to mitigate them. There are others that
we would attempt to mitigate even if they were very l-ow
and we had an accurate assessment of the cost and we said
1ow probability event, but it doesn't
let's do it, but the Company did not
costthat's a very
very much, so
provide that
v
el-aboration on
kind of information for my evaluation.
and I appreciate the
saying, then,
something will
Okay, fair
that, then,
enough,
so you don't
that there is too low of
happen with the existing
you're not
a probability that
Iine that they25
676
shouldn't mitigate by looking at a redundant llne, your
issue is more with the cost?
A My j-ssue is with the cost and with the
l-ack of gooC cost information, so as we talked, as Mr.
Wa1ker and I talked about, I believe that the Company
hasn't met a burden of proof to justlfy spending this
cost. That's not to say that there might not be some
rationale or some good reason for spending this money.
COMMISSIONER RAPER: Thank you. That's
aII I have, Dr. Morrison.
COMMISSIONER ANDERSON: Any other
questions from the Commission?
COMMISSIONER KJELLANDER: No.
COMMISSIONER ANDERSON: Redirect?
MS. HUANG: Nothing.
COMMISSIONER ANDERSON: Nothing.
MR. WALKER: Mr. Chairman?
COMMISSIONER ANDERSON: Yes.
MR. WALKER: I have an unusual request if
you would indulge me, please. I would request to be abl-e
to call Mr. Angell back up to the stand for the limited
purpose of addressing the information elicited on
cross-examination about whether the base case overhead
distribution is capable of serving peak 1oad, the fact
that the 60 megawatts and what was elicited on
CSB REPORTING
(208 ) 890-s198
617 MORRISON (Com)
Staff
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CSB REPORT]NG(2oB) B9o-s198
MORRISON
Sta ff
cross-examination was not contained in Mr. Morrison's
direct testimony, and I would ask that Mr. Ange1l that
the Company not be prejudiced by my ignorance about peak
load and the ability of the overhead distribution to meet
that or not and that Mr. Ange11 be given a very l-imited
opportunity on the stand to address that one singular
issue.
COMMISSIONER ANDERSON: You're asking the
rookle Chairman this. Without objection. I don't want
to set a precedent, so very 1imited if that's
MR. WALKER: Limited to that one issue
that was elicited on cross-examination that was not in
the direct testimony.
COMMISSIONER ANDERSON :
objection? Hearing none, please cal-l-
THE WITNESS: Can I go?
COMMISSIONER ANDERSON :
both have to sit
Do I hear
Mr. Angell.
Oh, I thought I
there. Thank youdj-d, sorry. No, you
for your testimony.
(The wj-tness left the stand. )
COMMISSIONER KJELLANDER: Mr. Wa1ker, do
you need five minutes?
five-minute break.
MR. WALKER: I apologize, y€s, I do.
COMMISSfONER ANDERSON: We'l-l- take a
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CSB REPORTING
(208 ) 890-s198
ANGELL (ReDi)
Idaho Power Company
MR. WALKER: Thank you, Mr. Chairman.
(Recess. )
COMMISSIONER ANDERSON: Mr. Walker, would
you l-1ke to re-cal-l- your witness?
MR. WALKER: Yes, I woul-d cal-I Mr. David
Angell, please. Thank you. May we approach with some
handouts ?
COMMISSIONER ANDERSON: Yes.
(Mr. Youngblood distributing documents. )
DAVID M. ANGELL,
produced as a witness at the instance of the fdaho Power
Company, having been previously duly sworn to te11 the
truth, the who1e truth, and nothing but the truth,
resumed the stand and was further exami-ned and testified
as foll-ows:
REDIRECT EXAMINATION
BY MR. WALKER:
O Mr. Angel1, you have in front of you two
discovery responses that are presently being handed out.
One is fdaho Power Company's response to Sierra Cl-ub's
request for production No. lB, and the other one is Idaho
Power Company's response to Commi-ssion Staff's requestt25
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for production No. 19. Are those the two documents that
you have?
A Yes, I do.
MR. WALKER: And I would ask that Idaho
Power's response to Sierra Club's request No. 18 be
marked as Idaho Power Exhibit No. 10, and that fdaho
Power's response to Staff's reguest No. 19 be marked as
Idaho Power Exhibit No. 11.
COMMISSIONER ANDERSON: Without objection,
done.
(Idaho Power Company Exhibit Nos. 10 and
11 were marked for identification. )
O BY MR. WALKER: Mr. Ange11, you were
present for the cross-examination of Staff witness
Mr. Morrlson?
A Yes, I was.
a And you heard the information about the
Company's sel-ected base case of overhead distribution not
being abl-e to meet the peak l-oad of the North Wood River
Va11ey and Mr. Morrison saying that reason is why it's
not an appropriate basei do you recall, that?
A Yes, I do.
O Do you have any information about that
overhead dlstribution base's ability to serve peak foad
of the North Wood River ValJ-ey?
CSB REPORTING
(208 ) 890-s198
ANGELL (ReDi)
Idaho Power Company
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CSB REPORTING
(208 ) 890-s198
ANGELL (ReDi)
Idaho Power Company
A Yes, I do.
O Could you please te1l us what that is?
A Yes; so first starting with the production
request 18 from Sierra and on that, ln that production
request, Table 18.1 lists the year of the peak load at
55.8 megawatts, so that's just the most recent peak that
we measured. Production request 19 to the third
production request of Staff speaks to the capability of
the overhead distrlbution option where each -- which is
abl-e to serve 65 megawatts of load, which is greater than
the historical peak that we have seen when each circuit,
distrlbution circuit, in the wintertime woufd be able to
carry the capacity of 13 megawatt.s per circuit and
there's five circuits.
MR. WALKER: No further questions,
Mr. Chairman. Thank you for allowing us to do that.
COMMISSIONER ANDERSON: Thank you, Mr.
Walker. f 'm going to al-l-ow ask a question, do any of
cross with thisthe intervenors have any
witness on the statements
fol1ow-up
that he's just made?
not, Mr. ChairmanMR. RICHARDSON: I do
MS. NUNEZ: Si-erra Club does.
COMMISSIONER ANDERSON: I'm sorry?
MS. NUNEZ: The Sierra Club does have one
question.o 25
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CSB REPORTING(208) 890-s198
ANGELL (X)
Idaho Power Company
COMMTSSIONER ANDERSON: Yes, Ms. Nunez,
please.
CROSS-EXAM]NATION
BY MS. NUNEZ:
O Mr. Angel1, oD this Exhibit No. 10 where
you state that the 1994-1995 winter peak was 55.5
megawatts and then this last winter it was 55.8, how come
the Company wasn't concerned about violating the
4O-megawatt standard when it revoked the 1995 CPCN or
when it went through that process to withdraw that? Why
wasn't that a concern then?
A I woul-d not say violate the standard, but
it was a concern at that point in time, and as was stated
earlier, w€ working through working with the community
was not able to si-te a transmission line with the
community and requested a revoking of the CPCN and
indicated that we woul-d come back in 10 years and look at
this again, so we did not completely violate or voj-d any
planning standard. Again, the planning standard directs
us once we hit 40, we look at all options possible in
order to provide that redundant transmission service.
O So at that time as part of the balance
between your concern about the 4O-megawatt issue and theI25
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public opposj-tion, the Company chose t-hat the public
opposition was more important than t.re planning
standard?
A I wouldn't say mor(: J-mportant. f t was
at that time we couldn't find a 'riable solution to build
the transmission l-ine.
MS. NUNEZ: Okay, thank you.
COMMISSIONER ANDERiON: Anyone else wish
to cross?
MS. HUANG: I do
COMMISSIONER ANTERSON: -Are you going to
redirect or do you want to cross?
.t
MS. HUANG: I wanted to cross.
COMMISSIONER ANDERSON: Okay, go ahead.
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BY MS. HUANG:
t,Y
Power filed in
demand reached
Do you have any
A
o
about 55.5 and
Mr. Ange.l-1,
this cas,e at
63 megawatts
, it indicates
the winter of
that?
the peak
2007 .
in the application that Idaho
paq: 4
during
reascn to question
No, I don't.
So although you have an exhibit that talks
55.8, it has in fact exceeded that;
CSB REPORTING
(208 ) 890-s198
683 ANGELL (Rex)
Idaho Power Company
RECROSS -EXAMINATION
correct?
A Yes.
0 Al-so, in your other exhibit when you
indicate in the production response 1,9 to Commission
Staff that the overhead distribution
you in
option wil-l be abl-e
fact had testifled in
A Yeah, the 60 I can explain that if you
want. The 60 megawatts is the summer rating of the
circuits,' whereas, the winter rating of the circuj-ts is
higher because of the cool-er
to serve up to 65 megawatts,
your direct testimony on page
megawatts; is that correct?
28 that 1t was 60
temperatures.
next sentence in theO And
production response
be able to serve up
A That
O And
limiting, I think,
A That
O
limits each
is, "Each distribution circuit will
to 13 megawatts"i is that correct?
is cor:rect.
you had testified earlier about
each circuit to 10 megawatts.
is correct.
then the
wil-l- be 13?
A Yeah, I wil-l- speak to that. That has to
do with our rel-iability planning, so the circui-ts
Iet's just take the summer capacity, so the capacity of
So why is it that the
circuit to 10 megawatts,
Company typically
but in this case it
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684 ANGELL (Rex)
fdaho Power Company
I 25
CSB REPORTTNG(208) B9o-s198
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CSB REPORTING(208) 890-s198
ANGELL (Rex)
Idaho Power Company
the circuits in the summer is 72 megawatts, which was
filed initially, with the total being 60. We
operate up to 10 megawatts unl-ess therers an
condition, and that emergency condition could
outage on an
pick up that
we implement
switches.
adjacent feeder where we want to
load as wel-l-, so, aqain, it goes
redundancy through the distribution tie
MS. HUANG: Thank you. I don't have other
questions.
COMMISSIONER ANDERSON: Thank you. Any
other intervenors?
only
emergency
be an
switch and
back to how
questions?
already done
cal-l- ?
MR. ADAMS: No questions.
COMMISSf ONER ANDERSON : Commj-ss j-oners, dny
f guess we don't need to redi-rect. You've
that, so do you have any other wi-tnesses to
MS. HUANG: No other witnesses.
COMMISSIONER ANDERSON: No other
wi-tnesses.
(The witness l-eft the stand. )
COMMISSIONER ANDERSON: I believe that
exhausts our witness list. Are there other issues that
need to come before the Commission today?Posthearing
al-l- good?briefs? Closing statements? Are we justI25
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CSB REPORTING(208) 890-s198
MR. WALKER: Pardon me, I didn't hear
that, Mr. Chairman.
COMMI SS IONER KJELLANDER : You shou]dn ' t
have.
COMMISSIONER RAPER: Never mind.
COMMISSIONER ANDERSON: Did you hear it
now? Okay, whil-e we're concluding here, f 'm just going
to go ahead and do a couple l-ittl-e housekeeping things.
One is that pursuant to Rule 267, all exhibits that were
identified during the hearing and to which no objection
was made are admitted into evidence, just a l-ittl-e
catchall for us up here.
(A11 exhibits previously marked for
identificatj-on were admitted into evidence. )
COMMISSIONER ANDERSON: Intervenor funding
requests under Rule 164 are due 1,4 days from today.
That's the other item that we need to di-scuss. Is there
anything else we need to dj-scuss? And public comment is
cl-osed as of now. I do want to thank everybody. I
appreciate everybody's input today. I reaIly do
appreciate the courteous conduct and I rea11y honestly
appreciate your forbearance with me at my first technicaL
hearing. I had great help on each side. I made a few
mistakes along the way, but thanks for not throwing any
the Commission willrotten fruit or vegetables at me, andt25
686 COLLOQUY
consider this record fu1ly developed and we will
deliberate on it and try to render a decision within the
timeline set before us, so with that, f don't know what
that time l-ine is. Do we need to it wil-l- be when we
get it done, so wlth nothing el-se to be said and our work
here complete today, we are adjourned. Thank you.
(The Hearing ad;ourned at 5227 p.m. )
681 COLLOQUYCSB REPORTING(208) 890-s198
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AUTHENTICATION
This is to certify that the foregoing
proceedings held in the matter of the application of
Idaho Power Company for a certifi-cate of public
convenience and necessity for the Wood River Va1Iey,
commencing at 9:30 d.fr., on Tuesday, August B, 2071, dt
the Commission Hearing Room, 412 West Washington Street,
Boise, Idaho, is a true and correct transcript of said
proceedings and the original thereof for the file of the
Commission.
Accuracy of alf prefiled testimony as
originally submitted to the Reporter and incorporated
herei-n at the direction of the Commi-ssion is the sole
responsibillty of the submitting parties.
A-e--
CONSTANCE S. BUCY
Certified Shorthand Reporter #1
\
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AUTHENTICAT]ON688CSB REPORTING(208) 890-s198
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