20211119Tidwell 1 to IPC.pdf

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BEFORE TTIE IDAHO PUBLIC UTILITIES COMMISSION
IN TIIE MATTER OF IDAI{O POWER
COMPANY'S PETITION FOR APPROVAL
OF A CUSTOMER SI.'RCHARGE AND
MODIFIED LINE ROUTE
CONFIGURATION FOR CONSTRUCTION
OF A NEW I38.KV TRANSMISSION LINE
IN TTM WOOD RIVER VALLEY
Case No. IPC-E-21-25
DrscovERY REQUEST #l
Kiki kslie A. Tidwell, Int€trrre,nor, hereby files a request for Discovery in Case IPC-E-
2l-25 prrsuant to the Rules of Procedure of the Idaho Public Utilities Commission, ID APA
3l-01.01 as follows:
l. The name and address of this Intervenor is:
Kiki Leslie A. Tidwell
704 N. River St. #1
Ilailey, ID 83333
(208)s78-7769
h!irru,v.(r,gz.,:.tu
2. In its most recent version of its 2021 Integrated Resource Plan hefened Alternative
Preliininar} Prcf'erreci l>ortl'olitr (iC4hopc".ryer.cqnr) Idaho Power has identified l0 MWs of
backup batteries to be distributed to zubstations in Idaho to rcducc costs of transmission
construction Have any of these backup batteries been slated for the substations in the Wood
I lD;scover) ltequcst # I IPC-E-21-25
River Valley? Can Idaho Power provide their current cost modeling forthese battery
installations?
3. Can Idaho Power provide any other irstance in its history where it has requird all
Idaho ratepayers to pay forthe transmission undergrounding costs for one city? Can Idatro
Power provide information on its denial of such a request by the City of Eagle?
4. Idaho Power's technicat guide, Class Cost-of-service Process Guide, states, "In order
to classiff a particular cost by component, primary attention is given to whether the cost varies
as a result of changes in the number of customers, changes in demand imposed by the customers,
or changes in energy used by the customers.... Demand-related costs are invesfuents in
generation, transmission, and a portion of the distribution plant and the associated operation and
rraintenance expenses necessary to accommodate the maximum demad imposed on the
Company's system . . . . The Company' s approach to cost allocation for transmission and
distribution facilities is an ef;fective method for equitably assigning costs to customer classes.
Under this method, tansmission and distibution costs are properly segmented according to the
manner in which the costs are imposed on the system. As a rcsult, the cost responsibility of each
class can be effectively identified through a combination of direct cost assignment and cost
allocation based on the appropriate demand- or customer-based factors." Sun Valley Company
has a coutract with ldaho Power as a Commercial Customer with lower per $kWhs rates.
However, after the Chrisnnas Eve power outage of 2009, this Contract Customer cbanged its
demand for backup power reliability; to impose on all ratepayers in Idaho the costs of a $35
million redrmdant tansmission line, including approximately $la milion of undergrounding
costs in Ketchum. Can Idaho Power provide information on why the costs of providing a new
transmission line to satisff the demand for additional reliability to one class of customers norttr
2f Discover] Request t1 IPC-E-2.|-J-i
oftho Wood Rivor substadm dow not oonstitrne a Chmge in Demd offi nostpopuly
assign€d to those custoffi rt{t.nostiog it, rmely Sun Valle,y R€soil?
DA-TED rt6 ?s/?t.1
{
I*:slie A- fidu,E-ll
Pro Se
$lDi$covsry Beguest #l IPC-H.-21-25
CTRTIIICATE O[' SEBYICE
I hereby certify that on this 19th day of November,202l,I caused to bc served a tnre and
conect copy of the foregoing by the method indicatd below, and addressed to the following:
ldaHydrc C. Tom ArkooshARKOOSH LAW OFFICES 802 West Bannock Street, Suite LP 103
P.O. Box 2900 Boise, ldaho 83701
U.S. Mail
OvernightMail
Hand Delivery
_Fan_X_ Ernail tom.arkoosh@a*oosh.com
Idaho Power Company, Donovan Walker,
_U.S. Mail
_Ovemieht Mail
_Hand Delivery
_Fax_X_ Email [e-mail]
Ron Williams, Hawley Troxell
_U.S. Mail
_OvernightMail
Fland Delivery
_ Fa:r
_X_ Email [e-mail]
Marfr [e-mail]
U.S.I\dail
OvernightMail
HandDelivery
_ Fax
_X_ Email Mark [e-mail]
Tim Graves, Blaine County
_U.S. Mail
OvernightMail
4lDiscotery Itequest #I IPC-U-21-25
_Hand Delivery
_Fa:r_X_ Email tgraves@co. blaine.id.us
Terri Carlock
_U.S. Mail
Overnight Mail
Hand Delivery
-Fax
_X_ Email [e-mail]
brmutlins@)rnu/aoalytics.com
U.S. Mait
Overnight }vlail
_HandDelivery_Fax_X_ Email [e-mail]
Keri Flawker
-U.S.
Mail
_OvernightMail
Hand Delivery
_Fax_X_ Email [e-mail]
John llarnmond
U.S. Mail
OvernightMail
Hand Delivery
_Fax_X_ Email [e-mail]
Ifiki trslie A.
SlDiscovery Request #1 IPC-F:-21-25