20040722Reply Comments.pdf

BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
P. O. Box 70 (83707)
1221 West Idaho Street
Boise , Idaho 83702
Telephone: [phone]
FAX Telephone: [phone]
Attorney for Idaho Power Company
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BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION
IN THE MATTER OF THE JOINT
APPLICATION OF DAHO POWER
COMPANY AND TAMARACK RESORT
llC FOR APPROVAL OF AN AGREEMENT
TO PROVIDE ELECTRIC DISTRIBUTIONFACILITIES.
CASE NO. IPC-04-
IDAHO POWER COMPANY'
REPLY COMMENTS
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and in accordance with IPUC Order No. 29509, herewith responds to several
comments received by the Commission in this case.
SUMMARY OF COMMENTS
Idaho Power has reviewed all of the comments directed to the
Commission. The Company will limit its reply comments to the comments filed by the
public, including comments from Mr. Andy Olavarria , 13960 Nisula Road , McCall, Idaho
whose comments are dated June 5, 2004 and by Mr. Terry Frisk, 2928 Autumn Way,
Meridian , Idaho, whose comments are dated June 15, 2004. Mr. Frisk represents that
he also owns property at 2253 West Mountain Road that is located approximately one
mile north of the Tamarack Resort.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page
Mr. Olavarria generally recommends that Idaho Power bury the proposed
transmission line between the Donnelly Substation and McCall that is intended to serve
the Tamarack Resort and other Company customers in the area.Mr. Olavarria
contends that the presence of overhead transmission lines near existing homes and
along the abandoned railroad corridor will "limit or detract" from the recreational use of
the former railroad right-of-way and will "adversely affect" the value of adjacent
properties. Mr. Olivarria does not expressly state who should bear the additional cost of
burying the transmission line. Idaho Power is aware that the Commission received
three other comments from members of the public also contending that transmission
lines in the Cascade-McCall area should be installed underground. These comments
expressed opinions similar to the opinions presented by Mr. Olavarria.
Mr. Frisk's comments appear to focus on the distribution line installed
along West Mountain Road in particular and between the Donnelly Substation and the
Tamarack Resort in general. Mr. Frisk encourages Idaho Power to bury the entirety of
the distribution line constructed to serve the Tamarack Resort. He generally maintains
that a buried distribution line would preserve the environment and improve reliability.
He notes that a portion of the Company s distribution line in the area has been buried
and endorses burying the remainder of the line for the resort area. In his comments
Mr. Frisk also objects to Idaho Power s tree maintenance practices.
REPLY COMMENTS OF IDAHO POWER COMPANY
Planning For Increased Loads in Valley County Idaho Power has
experienced continued growth in Valley County in the past twenty years. That growth
has resulted in significant increases in electrical usage in the area that is challenging
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 2
the Company s existing electrical facilities. In 1985, in anticipation of the continued
development of this resort area Idaho Power purchased right-of-way from the Union
Pacific Railroad between Donnelly and McCal1.1 The Company anticipated that this
corridor would be used for a future electrical transmission line route.
In 1999 and 2000, Idaho Power conducted a planning study of the
Donnelly/McCall area to determine the future electrical needs of the developing area
including the proposed Tamarack Resort, and to assure continued safe and reliable
electrical service within Valley County. The study concluded that the then-existing
overhead distribution line that served primarily seasonal residences and cabins did not
have the capacity to continue serving these uses as well as the proposed Tamarack
development, which, at build out , was expected to feature approximately 2000 homes
approximately 272 000 square feet of commercial space , a golf course, ski lifts and
other recreational amenities.
The Company s 1999-2000 planning study considered existing and future
loads, right-of-way requirements, environmental considerations, the location of existing
facilities and the overall cost in determining the most suitable means of providing
existing and future electrical service in Valley County. After considerable analysis , the
Company determined that the West Mountain Road corridor was part of the best route
to provide the projected electrical loads and that the former railroad right-of-way would
be part of the 138-kV transmission loop needed within the Donnelly/McCall area.
1 Idaho Power has sold certain portions of the former railroad right-of-way to adjacent property owners but, in all circumstances,
has retained a right-of-way easement over the conveyed portions of the corridor for future electrical facility uses.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 3
Underground Transmission Facilities Idaho Power does not own or
operate any underground transmission facilities.Installing of under-ground
transmission facilities is generally five to ten times more costly than placing the same
facilities overhead. To provide safe and reliable electrical service to its customers at the
least cost Idaho Power has not buried its transmission facilities.
The 138-kV transmission line between Donnelly and McCall will be
approximately twelve (12) miles long. A rule-of-thumb estimate for the cost of overhead
construction of a transmission line of the type currently contemplated for the 138-
Donnelly/McCall line is approximately $250,000 per mile or a total cost of approximately
$3 million.Using the above-referenced five to ten-times multiplier means that
constructing the McCall/Donnelly 138-kV line underground would cost approximately
$15 to $30 million depending on the topography of the route. Idaho Power would not
voluntarily incur these additional costs.However if a majority of Valley County
residents prefer that transmission facilities in the Donnelly/McCall area be buried, the
Company is willing to do so provided that the additional cost incurred by the Company
to place those facilities underground is borne by the residents of Valley County and not
the Company s customers generally.When certain of the Company s customers
determine that for aesthetic reasons the Company should conform to unique
construction standards that are substantially more expensive than the ordinary
standards in place in the balance of the Company s service territory when these unique
standards do not measurably increase system safety and reliability, the Company
believes that it is inequitable for the Company s ratepayers as a whole to absorb the
increased cost.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 4
Idaho Power believes overhead transmission facilities can be built
between McCall and Donnelly within the former railroad corridor that are sensitive to the
natural features of the area. The use of either wood poles or rust-colored , weathered
steel poles would blend in with the trees located along and through this corridor.
Furthermore, transmission poles can generally be placed farther apart which also
reduces the visual impact.
Underground Distribution Facilities: With respect to the distribution line
on West Mountain Road which was the subiect of Mr. Frisk's comment, Idaho Power
occasionally builds underground facilities rather than overhead facilities if it is more
cost-effective to do so. If this specific instance , Idaho Power applied the most cost-
effective solution possible to serve the Tamarack Resort load and t~ enhance the
reliability of the distribution feeder circuit in the area. In a one-mile section through
Forest Service land , it was more cost-effective for Idaho Power to bury the distribution
line. In that mile, insufficient right-of-way width existed to allow economical construction
of an overhead distribution line. Because of the constrained width of that right-of-way,
the Company would have been required to construct self-supporting structures to
accommodate the required turns in an overhead line.
Using self-supporting structures would have been more costly than
burying the line for the length of the segment located within the narrower right-of-way.
As a result, the Company elected to bury a portion of the distribution circuit serving the
Tamarack Resort and other loads in the area. Had sufficient right-of-way existed or
been available , it would have been more cost-effective for the Company to construct
that portion of the system in an overhead configuration.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 5
Idaho Power believes the overhead distribution facilities built within the
West Mountain Road corridor are sensitive to the natural features of the area. The
wood poles will blend in with the trees located along and through the corridor.
O&M Expense of Underground vs. Overhead Lines Several of the
comments received by the Commission stated that reduced O&M expense would justify
more expensive underground construction.Recent industry surveys of utility
experience with underground electrical lines have indicated that underground facilities
are not a cure-all for siting and reliability concerns. In general, underground lines are
equally reliable as overhead lines.Underground lines are subject to a somewhat
different set of threats than overhead lines. Underground lines have a slightly lower
frequency of failures; however, that benefit is offset by a much longer duration of an
outage until the failure can be located and repaired.Operational expenses are
generally similar. Expenses incurred to repair line failures are significantly higher for
underground lines.Evidence is accumulating that indicates that the life of
underground line may be significantly less than an overhead line because of the
degradation of the underground line s insulation. The difference may be a useful life of
30 years for underground facilities compared to a known useful life of 50 years or more
for overhead lines.
Idaho Power Company s Tree Maintenance Practices: The contractors
hired by Idaho Power Company to maintain the trees within the Company s electrical
transmission and distribution corridors are required to adhere to the Company s Line
Clearing Policy and Procedures.Most trees either removed or trimmed to
accommodate the power line upgrade in question were located in the public road right-
IDAHO POWER COMPANY'S REPLY COMMENTS , Page 6
of-way. Idaho Power has an agreement with Valley County to trim and remove trees
and brush located within the public right-of-way that either interfere or will interfere with
the Company s power lines.
For tree maintenance work completed in the vicinity of or adjacent to
private property, the Company s line clearing policies and procedures generally require
that all green brush four inches in diameter or smaller be chipped and that wood over
four inches in width be cut and left on the premises. Dead material cannot, for safety
considerations , be chipped and is also left on the site. It is the Company s experience
that most property owners in the Donnelly/McCall area salvage the wood generated by
the Company s line clearing efforts for firewood.
The Company requires its line clearing contractors to make a reasonable
attempt to notify each adjacent property owner of the line clearing work that is to
completed in the near future. Notification is in the form of a personal visit, a telephone
call or placement of a placard on the door of the property advising the inhabitants of the
property of the Company s line clearing policy and contact numbers. On July 31 , 2003
Idaho Power placed a placard on Mr. Frisk's property located at 2253 West Mountain
Road advising him of impending line clearing work. Between August 12-, 2003
Idaho Power line clearing contractors conducted work in the vicinity of Mr. Frisk'
home.
The line-clearing and vegetation management work in the Donnelly/McCall
area has been very successful and the Company has historically received very few
complaints from affected property owners living in this area concerning the Company
line-clearing efforts.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 7
DATED at Boise, Idaho, this 22nd day of July 2004.
(2MBARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of July 2004, I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S REPLY
COMMENTS upon the following named parties by the method indicated below , and
addressed to the following:
Lisa D. Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
P. O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
Hand Delivered
S. Mail
Overnight Mail
FAX
Steven J. Millemann
Millemann, Pittinger, McMahon &
Pemberton, LLP
706 N. Fi rst Street
O. Box 1066
McCall , Idaho 83638
Hand Delivered
S. Mail
Overnight Mail
FAX
Jean Pierre Boespflug
Tamarack Resort LLC
475 S. Capital Boulevard
Suite 200
Boise, Idaho 83702
wji~BARTON L. KLINE
CERTIFICATE OF SERVICE