20211210IPC to Tidwell 1.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]
December 10, 2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-21-25
In the Matter of the Application of Idaho Power Company’s Petition for
Approval of a Customer Surcharge and Modified Line Route Configuration
for Construction of a New 138 KV Transmission Line in the Wood River
Valley
Dear Ms. Noriyuki:
Enclosed for electronic filing, please find Idaho Power Company’s Response to the
First Discovery Request of Kiki Tidwell in the above matter. Please feel free to contact me
directly with any questions you might have about this filing.
Very truly yours,
Donovan E. Walker
DEW:cld
Enclosures
RECEIVED
2021 DEC 10 PM 2:41
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST DISCOVERY
REQUEST OF KIKI TIDWELL – 1
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S PETITION
FOR APPROVAL OF A CUSTOMER
SURCHARGE AND MODIFIED LINE
ROUTE CONFIGURATION FOR
CONSTRUCTION OF THE NEW 138 KV
TRANSMISSION LINE IN THE WOOD
RIVER VALEY

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CASE NO. IPC-E-21-25

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
DISCOVERY REQUEST OF KIKI
TIDWELL

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Discovery Request of Kiki Leslie A. Tidwell to Idaho Power Company
dated November 18, 2021, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST DISCOVERY
REQUEST OF KIKI TIDWELL – 2
REQUEST NO. 2: In its most recent version of its 2021 Integrated Resource Plan
Preferred Alternative Preliminary_Preferred_Portfolio (idahopower.com) Idaho Power
has identified 10 MWs of backup batteries to be distributed to substations in Idaho to
reduce costs of transmission construction. Have any of these backup batteries been
slated for the substations in the Wood River Valley? Can Idaho Power provide their
current cost modeling for these battery installations?
RESPONSE TO REQUEST NO. 2: The preliminary results shared in the
Integrated Resource Plan (“IRP”) Advisory Council Meeting held November 18, 2021,
identified the need for some distributed storage. Idaho Power plans to use this storage to
defer transmission and distribution investment, as well as to meet system capacity needs.
The specific location of these projects has not yet been finalized and the modeled costs
will be included in the forthcoming IRP, which will be filed by year end.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST DISCOVERY
REQUEST OF KIKI TIDWELL – 3
REQUEST NO. 3: Can Idaho Power provide any other instance in its history where
it has required all Idaho ratepayers to pay for the transmission undergrounding costs for
one city? Can Idaho Power provide information on its denial of such a request by the City
of Eagle?
RESPONSE TO REQUEST NO. 3: Idaho Power has not previously installed an
underground transmission line in its service area.
Regarding the City of Eagle, Idaho Power received authorization from the
Commission to construct an overhead 138 KV transmission line through the Eagle area
in 2004, under the Commission’s Order No. 29634 in Case No. IPC-E-04-4. Idaho Power
estimated the incremental cost of burying the 138 KV transmission line for this project at
$5-$6 million and stated that the City of Eagle would need to fund this underground cost,
because the transmission line could be constructed overhead without significant
restrictions. The overhead transmission line was not buried for this project, but the
Commission’s Order did approve a settlement between Idaho Power and the City of
Eagle, where the City increased its Idaho Power franchise fee from 1 percent to 3 percent
and committed the additional franchise fee funding towards burying certain existing Idaho
Power distribution lines within the City.
The response to this Request is sponsored by Pat Harrington, Corporate
Secretary, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST DISCOVERY
REQUEST OF KIKI TIDWELL – 4
REQUEST NO. 4: Idaho Power's technical guide, Class Cost-of-Service Process
Guide, states, "In order to classify 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 investments in generation, transmission, and a
portion of the distribution plant and the associated operation and maintenance expenses
necessary to accommodate the maximum demand imposed on the Company's system....
The Company's approach to cost allocation for transmission and distribution facilities is
an effective method for equitably assigning costs to customer classes. Under this method,
transmission and distribution costs are properly segmented according to the manner in
which the costs are imposed on the system. As a result, 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 contract with Idaho Power as a Commercial Customer with lower per
$kWhs rates. However, after the Christmas Eve power outage of 2009, this Contract
Customer changed its demand for backup power reliability; to impose on all ratepayers in
Idaho the costs of a $35 million redundant transmission line, including approximately $14
million of undergrounding costs in Ketchum. Can Idaho Power provide information on why
the costs of providing a new transmission line to satisfy the demand for additional
reliability to one class of customers north the Wood River substation does not constitute
a Change in Demand cost most properly assigned to those customers requesting it,
namely Sun Valley Resort?

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST DISCOVERY
REQUEST OF KIKI TIDWELL – 5
RESPONSE TO REQUEST NO. 4: Idaho Power’s proposed construction of the
138 kV Wood River-Ketchum transmission line (“Transmission Line”) is to provide a
second power source to all of its customers in the north Wood River Valley and is not
necessitated by growing demand by any individual customer in the area. Idaho Power
has explained at length that all customers served by the existing Wood River-Elkhorn-
Ketchum 138 kV transmission line face potentially severe and extended outage conditions
in the event of a failure of the existing transmission line. This threat faces all customers,
beginning with residential customers, who could lose electric heat and other critical
services in the event of a winter outage. Idaho Power’s longstanding efforts to construct
the Transmission Line have not focused on specific customers like the Sun Valley
Company. Instead, the focus has been on providing reliable service to the entire northern
Wood River valley community.
The response to this Request is sponsored by Pat Harrington, Corporate
Secretary, Idaho Power Company.

Respectfully submitted this 10th day of December 2021.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST DISCOVERY
REQUEST OF KIKI TIDWELL – 6
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 10th day of December 2021, I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY’S RESPONSE TO
THE FIRST DISCOVERY REQUEST OF KIKI TIDWELL upon the following named
parties by the method indicated below, and addressed to the following:

Blaine County Board of County
Commissioners
2016 1st Avenue South, Ste. 300
Hailey, ID 83333

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Tim Graves, Chief Deputy Blaine
County Prosecuting Attorney's Office
2191st Avenue South, Suite 201
Hailey, lD 83333
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Blaine County Land Use Department
c/o Tom Bergin
219 1st Avenue South, Suite 208
Hailey, ID 83333
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Ronald Williams
HAWLEY TROXELL ENNIS & HAWLEY
877 West Main Street, Suite 1000
Boise, Idaho 83702
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Kiki Leslie A. Tidwell
704 N. River St. #1
Hailey, ID 83333

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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST DISCOVERY
REQUEST OF KIKI TIDWELL – 7
John R. Hammond, Jr.
Dayne Hardie
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg. 8, Ste. 201-A
Boise, ID 83714
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C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701

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Christy Davenport, Legal Assistant