20040907Teinert Rebuttal.pdf

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ECEtVED (TJ
r~ I \ F n )...""BEFORE THE IDAHO PUBLIC UTILITIES! COMMISSION
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IDAHO POWER COMPANY.
CASE NO. IPC-E-O4-04
COMPLAINTANT .
VS.
THE CITY OF EAGLE , IDAHO.
RESPONDENT.
REBUTTAL AND SUPPLEMENTAL TESTIMONY OF
PIKE TEINERT
ON BEHALF OF
THE CITY OF EAGLE , IDAHO
Teinert, Rebuttal
City of Eagle
PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
My name is Pike Teinert and my business address is
834 Harcourt Road Boise, Idaho 83702.
ARE YOU THE SAME PIKE TEINERT WHO FILED DIRECT
TESTIMONY AND EXHIBITS IN THIS MATTER?
TESTIMONY?
I am.
WHAT I S THE SCOPE OF YOUR REBUTTAL AND SUPPLEMENTAL
will transmissionaddresstheproposedoverhead
line from Eagle Substation to the new Star Substation along the
route just North of and adj acent to State Street through the City
of Eagle to the new Star Substation.
HAVE YOU REVI EWED THE DIRECT TE S T IMONY THE
COMMISSION STAFF , IN THIS MATTER?
TESTIMONY?
Yes.
DO YOU HAVE ANY OVERALL OBSERVATIONS REGARDING THAT
Yes.Staff addressed many issues In its testimony,
but it does not recommend an acceptable solution that can both
satisfy the Ci ty ' s obj ections and meet the Company goal
serving the new Star Substation.
T einert, Rebuttal
City of Eagle
WHAT WOULD BE AN ACCEPTABLE SOLUTION FOR BOTH PARTIES
IN THIS CASE?
A. The Company has stated that it wants to provide service
to the new Star Substation from the existing Eagle Substation and
the City s position is to minimize the impact of sub-transmission
service the SubstationStar its residential andnew
commercial property the Citycost itsowners
citizens.I f both the City and Company posi tions could be
realized with the sub-transmission line and route,same
acceptable solution could be reached.
BEGINNING WITH THE PURPOSE AND ROUTE OF THE PROPOSED
LINE DOESN'T THE STAFF IN SEVERAL PLACES IN ITS TESTIMONY STATE
THAT THE PURPOSE OF THE PROPOSED LINE IS TO SERVE THE NEW STAR
SUBSTATION?
Yes.On page 2 , line 7-11, the Staff states that:
Simply stated,Idaho Power Company needs to extend its
sub transmission facili ties from the existing substation through
the City of Eagle to the new Star Substation.
Addi tionally, on page 4, line 2-6, the Staff states:
T einert, Rebuttal
City of Eagle
The City of Eagle has denied Idaho Power request to
itsextend overhead transmission facili ties from the Eagle
substation westward through the ci ty to the Star substation.
Based on these statements in the Staff's Testimony and the
City s response to the Company complaint in this case it
clear that both the Ci ty and the Staff understand the Company
request to build sub-transmission line to serve the new Star
Substation.
Q. WHY IS IT IMPORTANT TO EMPHASIZE THE STAFF'S AND THE
CITY'S UNDERSTANDINHG OF THE COMPANY'S REQUEST FOR AN OVERHEAD
TRANSMISSION LINE THROUGH THE CITY OF EAGLE?
Because the Company in its CUP applications,its
subsequent meetings with City staff and ul timately this
complaint did not reveal the real reason for the proposed 138kV
line to the City or the Commission Staff.
WHAT I S THE COMPANY'S REAL REASON FOR THE PROPOSED
HIGH CAPACITY 138KV TRANSMISSION LINE?
The City s Exhibit No. 114 , Idaho Power Company
Year Transmission Plan for the Treasure Valley,Buildout
Proj ection Distribution Planning 2002-2012, Page 11 under Locust
Loop No.2 states:
Teinert, Rebuttal
City of Eagle
The Locust-Eagle 138 will be built when the reliability
of service is at risk or when the Gary tap is opened because
the State 138kV conversion. The Star tap is a tap in the Locust-
Eagle line for temporary service to Star.The Locust No.2 is
completed with the Locust-Eagle 138kV construction and will serve
Joplin Eagle loads and loads north of the Beacon Light
The Eagle-Ustick 138kV linearea.tie theserves
cloverdale source. A source in the north Star area will serve the
Star Substation.
Clearly the need to the SubstationStar onlyserve
temporary.The Star tap is a tap in the Locust-Eagle line for
temporary service to Star.
" "
A source in the north Star area will
serve the Star Substation." The Company did not disclose that the
proposed Eagle Substation service to the new Star Substation was
only temporary.
Also and more importantly,the Company did not disclose
the real reason for the high capacity 138kV line as stated in the
third sentence of the quote. "The Locust Loop No.2 is completed
wi th the Locust-Eagle 138kV construction and will serve H.
Joplin,Eagle loads and loads north of the Beacon Light area.
Clearly this high capacity 138kV line,which is the same line
being contested in this case , must have the capacity to carry the
load for the Joplin and Hewlett-Packard Substations as well
the Eagle Substation load and benefi ts customers served from the
Joplin and Hewlett-Packard substations too.
T einert, Rebuttal
City of Eagle
The Company did not disclose this information in its CUP
application the City,in meetings with the City Staff
Council, or In its complaint in this case. And the City of Eagle
has been unfairly compelled to use its limited time and financial
respond Idahoresources Power claim this dispute
al though customers served the Jopl in and Hewlett-Packard
Substation clearly benefi t from the high capacity 138 kV line.
Pages and Exhibi t 114 confirm that the
Company loop model the first line sections from the source
substation, such as the Locust-Eagle 138kV line, must have enough
capacity to carry all of the substations on the loop. Therefore,
the Locust-Eagle 138kV line must have the capacity to carry all
of the load on the Eagle, Joplin and Hewlett- Packard Substations
a t the same time.
Addi tionally,the Company request for a high capacity
138kV line from the Eagle Substation to the new Star Substation
is not the Star Substation s permanent source, but instead, the
first phase of the Locust-Eagle 138kV line to complete the Locust
Loop No.
If the City and the Commission Staff had known that the new
Star Substation feed from Eagle Substation was only temporary and
that the real reason for the high capacity 138kV line was
complete the Locus t Loop No.the search for acceptable
solutions would have been much more focused, easier to analyze,
less contentious and significantly less time consuming.
T einert, Rebuttal
City of Eagle
WHY WOULD THE CITY AND THE STAFF HAVE BEEN ABLE TO PURSUE
MORE ACCEPTABLE SOLUTIONS?
The City and Staff both believed that the Company
request for a high capacity 138kV line was needed to serve the
existing and future loads in the Star and Eagle area as stated by
the Compan y its Testimony.The real for the highreason
capaci ty 138 kV line Eagle,Joplin and H. P.serve
Substations, is to complete the Locust Loop No., a much larger
load than the capaci ty of the new Star Substation. Based on the
Company 10 Year Transmission Plan , City Exhibit No.114, page
No. 48, first paragraph , the first line section, the Eagle-Locust
138kV line, in the 138kV Locust Loop No.2, is rated as a getaway
section 277 MVA.thecontrast,new Star Substation
transformer rated from 20-aboutMVA tenth of theone
capaci ty the Company plans for the high capaci ty Eagle-Locust
138kV line.
Therefore,al though the City and Staff have been led to
believe that the proposed high capacity 138kV line was needed to
serve the Star Substation,the Company 10 Year Transmission
Plan contradicts the Company s testimony and explains that it'
real the completion thepurpose Locust Loop ,No.2 .
Therefore,the City and Commission Staff have been developing
al ternati ves wi thout the benefit of valid data and information.
T einert, Rebuttal
City of Eagle
The Ci ty and Commission Staff could have more thoroughly
analyzed smaller capacity solutions,like 69kV transmission to
serve the new Star Substation capaci ty, had the Company disclosed
the size of the Star Substation load, and that the Eagle feed to
new Star Substation was only temporary.
The Company s failure to disclose the real reason for the
high capaci ty 138 kV line created extremely complex and
contentious environment in which a solution to this dispute has
not been found after more than four years since the Company first
approached the City in late 1999 with its request to serve the
proposed Star Substation.
HAS THE STAFF INDICATED IN ITS TESTIMONY THAT THEY
MADE AN ANALYSIS OF THE 69KV OPTION YOU RECOMMENDED IN YOUR
TE S T IMONY ?
No. The Staff however , did state in its testimony on
line reference to the 69kV option using ACSSpage
conductor,that they believed had potential provide
addi tional transmission capacity at reasonable cost.
The Staff further says,beginning on line 23 of page
that they would look to the Company to explain why ACSS would not
viable alternative expand the capaci ty existing
facilities.
HAS THE COMPANY PRODUCED ANY DOCUMENTS DETAILING ITS
ANALYSIS AND DECISION NOT TO USE ACSS?
Teinert, Rebuttal
City of Eagle
A. No , it has not.
Q. SINCE THE COMMISSION STAFF HAS NOT OFFERED A 69KV
ALTERNAT IVE SERVING THE NEW STAR
SOLUTION WOULD REQUIRE CAPACITY THAT
CAPACITY NEEDED FOR THE LOCUST LOOP NO.
SOLUTION THAT WILL MEET THE CITY'S REQUIREMENTS AND PROVIDE
CAPACITY TO SERVE THE NEW STAR SUBSTATION?
SUBSTATION 69KVAND
MUCH LESS THAT THE
IS THERE A 69KV
Yes,the new Star Substation transformer capacity
about 20-30 MVA. A 69kV line using AcSR all aluminum or AcSS
conductor can provide the needed transmission capacity to serve
the transformer load at the new Star Substation. In addition to
the 69kV transmission line, an autotransformer would be required
the Eagle substation.Thesenear step-down 138 kV / 69kV
autotransformers are available on the after-market , are excellent
equipment for applicationstemporary and
deli vered time themeet Company
completion date.
PAGE BEGINNING AT LINE
can andordered
proposed May 2005
THE STAFF LISTS
ALTERNATIVES AVAILABLE TO THE COMMISSION IN ITS DECISION. DOES
THIS 69KV LINE ALIGN WITH THE ALTERNATIVES?
Yes, the 69kV line aligns with the recommended Commission
al ternati ves Nos. 1, 4) and 5) respectively,directs the Company
to extend its overhead facili ties through Eagle and directs the
Teinert, Rebuttal
City of Eagle
Company lower alignmentoverheadcostpursue
combination of these alternatives.
THE STAFF'S DIRECT TESTIMONY FURTHER RECOMMENDS
BEGINNING ON PAGE LINE THAT THE COMMISSION SHOULD DIRECT
THE COMPANY TO INSTALL OVERHEAD FACILITIES. WOULD THE 69KV LINE
ALIGN WITH THIS RECOMMENDATION BY THE STAFF?
Yes,the 69kV overhead line would comply with this
recommendation also.
Q. ON PAGE BEGINNING ON LINE 19 THE STAFF SAYS THAT " IT
UNLIKEL Y THAT PREVIOUSLY PROPOSED OVERHEAD ALIGNMENT
ADJACENT TO STATE STREET THROUGH THE CITY WOULD BE ANY MORE
ACCEPTABLE." DO YOU AGREE THAT THIS ALIGNMENT IS UNACCEPTABLE TO
THE CITY?
becauseNo,the Staff referring the highwas
capacity 138kV line previously proposed to the City and not the
69kV line that could provide the temporary feed to the new Star
Substation and would be much less obtrusive. A 69kV line from the
Eagle Substation along the alignment referenced by the staff
alongwest State has previouslyStreet,used this route
existing poles before the Company reconfigured the line as
distribution feeder from the Eagle Substation. The City would not
obj ect to the re-conversion of the line to 69kV service to feed
the new Star Substation.
Teinert, Rebuttal
City of Eagle
Q. ON PAGE 9 , BEGINNING ON LINE 13 , THE STAFF SAYS THAT
THE STATE STREET ALIGHNMENT MAKES THE MOST ECONOMICAL SENSE FOR
THE GENERAL BODY OF IDAHO POWER CUSTOMERS. DO YOU AGREE?
A. Yes, I believe that if the Company completes a detailed
design and analysis the 69kV al ternati ve,cost will
illustrate costthatthe69kV alternative will less than the
138kV high capacity alternative to temporarily serve the new Star
Substation. This solution will therefore have less impact on the
general body of Idaho Power customers as well as the City
Eagle.
Q. ARE THERE ADDITIONAL ISSUES RAISED BY THE STAFF IN ITS
DIRECT TESTIMONY THAT ARE PROBLEMATIC FOR THE CITY?
A. Yes the Staff says on page 3, beginning on line 5 and
agaln on page 9, beginning on line 4 that the Company should be
allowed reasonably extend and itsupgrade overhead
transmission/ distribution facili ties de ems appropriate.
However, the Staff does not include in this part of its testimony
any recommendation for tests or checks and balances that will
ensure that the Company s planning and design for such facilities
include both the customer interests.and the Company best
Especially in contested extension of facilities, as in this case,
such checkssystem and balances would have quickly
identified the Company real for the proposed highreason
T einert, Rebuttal
City of Eagle
capacity 138kV line.A mandatory system of planning and design
tests and checks and balances would have identified the separate
functions of the Company s proposed line,one,a high capaci t y
138kV line designed to complete the Locust loop No.2 and two, to
provide temporary service to the new Star Substation.The City
and the Company could have focused their discussions clearly on
the temporary service of a low capacity sub-transmission line to
serve the Star Substation.
this exceSSl ve time has beenamoun tcase,
required to extract the details of the Company s plan for the
high capaci t 138 kV ine .Therefore,the Commission
establishes a policy that allows the Company to reasonably extend
its overhead facili ties,then the Commission at the same time
must also establish system of tests,checks and balances for
the Commission Staff to analyze the Company s plans and designs
for those extensions in disputed instances.
As examples, in this dispute, the City and the Staff were
not given essential design data including,but not limited to:
the proposed sub-transmission line electrical loads,the
temporary load requirements for the new Star Substation feed from
Eagle the electrical load requirements the 138kV high
capacity line complete the Locust the timingLoopNo.
associated with the completion of the Locus t Loop No.the
routing of the proposed Locust Loop No.through the city of
Eagle, and the Company s standard design specifications for 138kV
Teinert, Rebuttal
City of Eagle
and 69kV sub-transmission lines. Although the Staff may not be
comfortable with analyzing data at this level of detail,it
essential information necessary to analyze plans and design for
contested Company proj ects.
If the Commission required and the Staff reviewed this
type essential information its test forpart
reasonableness,the City,the Company and the Commission Staff
would have been able to quickly identify potential solutions in
this dispute.
Q. IN CONCLUSION , WILL YOU PLEASE SUMMARIZE YOUR REBUTTAL
AND SUPPLEMENTAL TESTIMONY?
A. Yes, in summary the Staff has been unable to provide an
acceptable solution for this dispute primarily because the
Company did not disclose the real reason for the proposed high
capacity 138kV line.
An overhead 69kV line solution routed on the old 69kV line
right-of-way going West from the Eagle Substation is acceptable
to the City as temporary service to the new Star Substation and
with the alternatives the Staff recommends theagrees
Commission in its testimony.
Also, the Staff's recommendation to the Commission that
should allow the Company reasonably itsextend overhead
deli very facili ties accompanied bymust requirement for
detailed planning and design data to enable the Staff to ensure
Teinert, Rebuttal
City of Eagle
equitable solutions for all parties.Had the Company disclosed
its real reason for the high capacity 138kV line and provided
this detail in the ini tial request to the City, all parties could
have agreed on a solution very early in the process.
Q. DOES THIS CONCLUDE YOUR TESTIMONY.
A. Yes.
T einert, Rebuttal
City of Eagle