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HomeMy WebLinkAbout20161108Youngblood Direct.pdfRECEIVE D BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FOR A ) CASE NO. IPC-E-16-28 CERTIFICATE OF PUBLIC CONVENIENCE ) AND NECESSITY TO CONSTRUCT SYSTEM ) IMPROVEMENTS TO SECURE ADEQUATE ) AND RELIABLE SERVICE TO CUSTOMERS ) IN THE WOOD RIVER VALLEY. ) ) IDAHO POWER COMPANY DIRECT TESTIMONY OF MICHAEL J. YOUNGBLOOD 1 2 Q. A. Please state your name and business address. My name is Michael J. Youngblood and my 3 business address is 1221 West Idaho Street, Boise, Idaho 4 83702. 5 6 Q. A. By whom are you employed and in what capacity? I am employed by Idaho Power Company ("Idaho 7 Power" or "Company") as the Manager of Regulatory Projects 8 in the Regulatory Affairs Department. 9 10 Q. A. Please describe your educational background. In May of 1977, I received a Bachelor of 11 Science Degree in Mathematics and Computer Science from the 12 University of Idaho. From 1994 through 1996, I was a 13 graduate student in the Executive MBA program of Colorado 14 State University. Over the years, I have attended numerous 15 industry conferences and training sessions, including 16 Edison Electric Institute's "Electric Rates Advanced 17 Course." 18 Q. Please describe your work experience with 19 Idaho Power. A. I began my employment with Idaho Power in 20 21 1977. During my career, I have worked in several 22 departments of the Company and subsidiaries of IDACORP, 23 Inc., including Systems Development, Demand Planning, 24 Strategic Planning and IDACORP Solutions. From 1981 to 25 19 88 , I worked as a Rate Analyst in the Rates and Planning YOUNGBLOOD, DI 1 Idaho Power Company 1 Department where I was responsible for the preparation of 2 electric rate design studies and bill frequency analyses. 3 I was also responsible for the validation and analysis of 4 the load research data used for cost-of-service 5 allocations. 6 From 1988 through 1991, I worked in Demand Planning 7 and was responsible for the load research and load 8 forecasting functions of the Company, including sample 9 design, implementation, data retrieval, analysis, and 10 reporting. I was responsible for the preparation of the 11 five-year and 20-year load forecasts used in revenue 12 projections and resource plans as well as the presentation 13 of these forecasts to the public and regulatory 14 commissions. 15 From 1991 through 1998, I worked in Strategic 16 Planning. As a Strategic Planning Associate, I coordinated 17 the complex efforts of acquiring Prairie Power Cooperative, 18 the first acquisition of its kind for the Company in 40 19 years. From 1996 to 1998, as a part of a Strategic 20 Planning initiative, I helped develop and provide two-way 21 communication between customers and energy providers using 22 advanced computer technologies and telecommunications. 23 From 1998 to 2000, I was a General Manager of 24 IDACORP Solutions, a subsidiary of IDACORP, Inc., reporting 25 to the Vice President of Marketing. I was directly YOUNGBLOOD, DI 2 Idaho Power Company 1 responsible for the direction and management of the 2 Commercial & Industrial Business Solutions division. 3 In 2001, I returned to the Regulatory Affairs 4 Department and worked on special projects related to 5 deregulation, the Company's Integrated Resource Plan, and 6 filings with both the Idaho Public Utilities Commission 7 ( "Commission" or "I PUC") and the Public Utility Commission 8 of Oregon. 9 In 2008, I was promoted to the position of Manager 10 of Rate Design for Idaho Power. In that position, I was 11 responsible for the management of the rate design 12 strategies of the Company as well as the oversight of all 13 tariff administration. 14 In January of 2012, I became the Manager of 15 Regulatory Projects for Idaho Power, which is my current 16 position. In this position, I provide the regulatory 17 support for many of the large individual projects and 18 issues currently facing the Company. I provided the 19 regulatory support for the inclusion of the Langley Gulch 20 power plant investment in rate base, supported the 21 Company's efforts to address numerous issues involving 22 Qualifying Facilities ("QF") as defined under the Public 23 Utility Regulatory Policies Act of 1978 ("PURPA"), 24 including the Company's efforts in Case No. GNR-E-11-03, 25 the review of PURPA QF contract provisions. I provided YOUNGBLOOD, DI 3 Idaho Power Company 1 direct testimony for the Company in its Idaho application 2 for a Certificate of Public Convenience and Necessity 3 ("CPCN") for the investment in selective catalytic 4 reduction controls on Jim Bridger Units 3 and 4, IPUC Case 5 No. IPC-E-13-16, the Company's request to implement solar 6 integration rates and charges based upon the initial 2014 7 Study, IPUC Case No. IPC-E-14-18, as well as the Idaho case 8 to update those integration costs with the 2016 Study, IPUC 9 Case No. IPC-E-16-11. 10 Q. What is the purpose of your testimony in this 11 matter? 12 A. The purpose of my testimony is to provide an 13 overview of the Company's case and its request, pursuant to 14 Idaho Code§§ 61-508 and 61-526, that the Commission find 15 it to be in the public convenience and necessity that Idaho 16 Power construct a new 138 kilovolt ("kV") transmission line 17 and related facilities to provide a redundant source of 18 energy into the northern portion of the Wood River Valley 19 north of East Fork Road, including the communities of 20 Ketchum and Sun Valley and portions of Blaine County 21 ("North Valley"). The North Valley is currently supplied 22 by a 54-year-old, single-source radial line that 23 experiences sustained outage line events, which are 24 projected to increase in frequency. The North Valley is 25 YOUNGBLOOD, DI 4 Idaho Power Company 1 the second largest load center in Idaho Power's service 2 territory served by one radial transmission line. 3 The proposed facilities are necessary and required 4 in order to continue providing reliable and adequate 5 electricity to Idaho Power's customers in the North Valley. 6 7 8 case. 9 Q. A. I. OVERVIEW Please provide an overview of the Company's In this case, the Company will support its 10 request for a CPCN by discussing Idaho Power's need to 11 construct a new transmission line in the Wood River Valley, 12 provi ding background information including extensive public 13 and community outreach and involvement, and discussing the 14 various redundant service alternatives considered and line 15 route options that support the request in this case. In 16 his direct testimony, Company witness David Angell will 17 discuss why the Company must construct facilities between 18 the substations in Hailey and Ketchum to meet its 19 continuing obligation to serve customers located in the 20 North Valley. He will also discuss the Company's long 21 history of planning for a second transmission line and the 22 cooperative efforts taken between Idaho Power and the 23 people in the communities of Sun Valley, Ketchum, and 24 Blaine County. This collaborative process was intended to 25 find agreement on the purpose and need for a redundant YOUNGBLOOD, DI 5 Idaho Power Company 1 source of energy and to determine the scope and feasibility 2 of a route that could be obtained and permitted. 3 Mr. Angell will discuss a number of construction 4 configurations the Company considered, both standard 5 practice and non-standard, to provide redundant service to 6 the North Valley, ultimately determining three viable 7 construction configurations for further analysis, which he 8 provided to Company witness Ryan Adelman. Mr. Adelman's 9 direct testimony will detail the costs, benefits, and 10 detriments of each of the viable construction 11 configurations, as well as providing cost estimates on 12 three additional options for one specific construction 13 configuration. Mr. Adelman concludes by identifying both 14 the Company's standard practice construction configuration 15 for building a redundant electrical solution, given the 16 cost estimates and the constraints of the North Valley, as 17 well as an economically equivalent alternative route, which 18 is the route for which the Company is requesting a CPCN be 19 issued. 20 Q. What were the three viable construction 21 configurations for providing redundant service to the North 22 Valley? 23 A. As more fully described in Mr. Adelman's 24 testimony, the three redundant service construction 25 configurations were identified as: (1) Underground YOUNGBLOOD, DI 6 Idaho Power Company 1 Transmission, (2) Overhead Distribution, and (3) 2 Underground Distribution. 3 Q. Which construction configuration did the 4 Company determine as the economic base case for providing 5 redundant service to the North Valley? 6 A. As described in Mr. Adelman's testimony, the 7 Overhead Distribution construction configuration was the 8 lowest-cost viable alternative, as well as the traditional 9 or standard practice for providing redundant electrical 10 service to an area and therefore became the basis for 11 comparison of other construction configurations. 12 Q. Would the Overhead Distribution base case be 13 considered one of the typical or standard construction 14 configurations applied by the Company when addressing the 15 need for redundant electrical service? 16 A. Yes. Based on discussion with Mr. Angell and 17 Mr. Adelman, the Company's traditional practice to reduce 18 the likelihood of sustained outages would be to construct 19 multiple overhead transmission lines (a redundant 20 transmission source) or to implement distribution circuits 21 with tie switches in order to continue providing customers 22 with reliable electric service. The Overhead Distribution 23 base case meets these criteria. However, while the 24 Overhead Distribution construction configuration was the 25 lowest-cost viable solution and would provide redundant YOUNGBLOOD, DI 7 Idaho Power Company 1 service to the North Valley, there would be some challenges 2 for the actual construction of this route, the land 3 acquisition required for the substation and other 4 facilities, and aesthetic concerns that warranted a look at 5 other alternatives. More specifically, ordinances in 6 Ketchum and Sun Valley requiring that all new electrical 7 facilities be constructed underground would make it more 8 difficult to construct overhead distribution lines because 9 of the communities' concern of visual impact on the area. 10 The Underground Transmission construction 11 configuration, with a similar range in cost estimates to 12 the lowest-cost Overhead Distribution base case, would also 13 provide redundant service. In addition, the Underground 14 Transmission construction configuration would provide 15 additional capacity, enabling future growth within the 16 area. The range in estimated costs for the Underground 17 Transmission construction configuration was dependent on 18 the location of the transition point from overhead-to- 19 underground transmission. The further along the path that 20 construction can remain above ground reduces the overall 21 total cost of the project. As described in Mr. Adelman's 22 testimony, three separate options to the Underground 23 Transmission construction configuration, with varying 24 overhead-to-underground transition points ("TP"), were 25 analyzed further: TPl, near the intersection of Elkhorn YOUNGBLOOD, DI 8 Idaho Power Company 1 Road and Highway 75; TP2, near the intersection of Hospital 2 Drive and Highway 75; and TP3, near the intersection of Owl 3 Rock Road and Highway 75. The TPl option, near the 4 intersection of Elkhorn Road, resulted in the lowest-cost 5 estimate for the Underground Transmission construction 6 configuration. The cost estimate for the TPl option was 7 essentially equivalent to the lowest-cost estimate of the 8 Overhead Distribution base case. 9 Q. Is the TPl route, at Elkhorn Road, the option 10 for which the Company is requesting a CPCN? 11 A. Yes. The Company's request is for the 12 Commission to find that the present and future public 13 convenience and necessity require the construction of a new 14 138 kV transmission line and related facilities to provide 15 a redundant source of energy into the North Valley. Both 16 of the viable options require the construction of a new 17 overhead 138 kV transmission line from the Wood River 18 station to a location near the intersection of Highway 75 19 and Owl Rock Road, referred to as the Common Route. From 20 that point north, either the TPl option or the Overhead 21 Distribution base case would provide the necessary 22 facilities to provide a redundant source of energy to the 23 North Valley, and are both economically equivalent. 24 However, the TPl option will provide additional stability 25 over time as it will allow for future growth in customer YOUNGBLOOD, DI 9 Idaho Power Company 1 demand . The Underground Transmission construction 2 configuration would provide full redundant capacity of the 3 existing 138 kV transmission line and would support a 4 build-out demand in the North Valley area of 120 megawatts 5 ("MW ") . The line would provide the ability to de -energize 6 any section of either transmission line for maintenance , 7 inspection , repair, or reconstruction , without customer 8 int erruption . The co nstruction of the Underground 9 Transmission TPl option is the Company's requested route 10 for the Commission 's CPCN consideration . 11 12 Q. II. FUNDING ALTERNATIVES Would the other Underground Transmiss i on 13 options also provide the same benefits as the TPl opt i on? 14 A. Yes , however , at incrementally greater cost . 15 The estimated cost for TP2 is an additional $2 .7 million at 16 $32 .7 million and TP3 is an additional $5 .7 million over 17 the Overhead Distribution base case at $35 .7 million . 18 Q. Were all communities in agreement with the 19 selection of TPl? 20 A. No . There was interest expressed in putting 21 as much of the redundant line underground as possible ; 22 however , representatives for the communities were concerned 23 about the need to pay for the incremental costs for the 24 additional underground transmission line through a Local 25 Improvement District ("LID"), which would assess the YOUNGB LOOD , DI 10 Idaho Power Company 1 additional dollars based upon the North Valle y property 2 values . The Community Advisory Committee ("CAC") was 3 concerned that it would be very difficult to get an LID 4 approved . 5 Q. Did anyone in the community suggest that the 6 line should be placed underground regardless of the 7 location and cost? 8 A. At first, some members of the CAC suggested 9 that there should not be any incremental costs because of 10 the city ordinances restricting new overhead construction . 11 Q. What was Idaho Power's response to the 12 assertion that local communities should not be required to 13 fund the incremental costs of non-standard designs? 14 A . Idaho Power explained to the CAC that the 15 Company is obligated to build its infrastructure in the 16 most cost -effective manner possible . Idaho Power develops 17 transmission project designs throughout its service 18 territory that provide the least-cost solution while 19 adhering to consistent standards for service and that the 20 IPUC allows recovery of those reasonably incurred costs. 21 To the extent that customers or communities desire the 22 Company to pursue alternate designs, such as underground 23 transmission at a higher cost, it is the Company's 24 position , as previously supported by the IPUC ,1 that the 1Case No . IPC-E-04 -04 , Order No . 29634 . YOUNGBLOOD , DI 11 Idaho Power Company 1 customers requesting and benefiting from the alternate 2 design are responsible for the incremental cost 3 differential between t he lowest -cost standard practice 4 option and the desired option . 5 Q. What was the CAC 's response to the Company 's 6 position that the incremental costs should be recovered 7 from the North Valley community? 8 A. The CAC was still concerned that it may not be 9 possible to get an LID approved and asked if the Company 10 would consider adding the incremental costs as a surcharge 11 to the customers ' electric bills . The Company is not 12 generally in favor of collecting additional costs related 13 to meeting the preferences of a community on customers ' 14 electric bills , and at first resisted . However , in an 15 attempt to reach a compromise and begin construction on a 16 much -needed project , the Company reconsidered its pos i tion . 17 Q. What wa s the result of the Company 's 18 reconsideration? 19 A . In looking at the three transition-point 20 options for the Underground Transmission construction 21 configuration , the Company considered possible funding 22 arrangements . The funding options are summarized in the 23 following table : 24 25 YOUNGBLOOD, DI 12 Idaho Power Company 1 2 3 Table 1 : Transition Point Funding Options Underground Transition Point TPl -El khorn Road TP2 -Hospital Drive TP3 -Owl Rock Road Q. Total Cost Incremental Surcharge Esti mate Cost Collection Method Rate/Duration $30 .0 M $0 .0 M N/A N/A $32 .7 M $2 .7 M Su r charge/Franchise 3%/-10 years Fee $35 .7 M $5 .7 M LID Please explain the table above . 4 A. For the three transition point options for the 5 Underground Transmission construction configuration , TPl, 6 TP2, and TP3, the incremental cost ranges from $0.0 to $5 .7 7 million. I f the local jurisdi ctions supported the TPl 8 option , there wou l d be no inc r emental costs above the 9 lowest-cost economic base case ; therefore , no additional 10 incremental costs would need to be recovered from the North 11 Valley residents . However , i f the community 's choice was 12 for either of the other two transit i on point options , the 13 additional incremental costs would need to be recovered 14 from the customers directly benefiti ng from the redundant 15 facilities . The Company proposed that if the third option 16 was chosen , the incremental costs of $5 .7 mi llion were of 17 sufficient magnitude that they should not be recovered as a 18 surcharge on customers ' electric b i lls , but should be 19 recovered through an LID , a s had been suggested before . 20 However , if the community wanted opt i on TP2 , with the 21 underground transition poi nt a t Hospital Drive , the YOUNG BLOOD , DI 13 Idaho Power Company 1 incremental costs would be approximately $2 .7 million above 2 the economic base case. The Company agreed that if the 3 communities chose this option for the trans i tion point of 4 the Underground Transmission line, the Company wo uld add a 5 3 percent surcharge to the North Valley c ustomers' bills, 6 with the caveat that any city franchise fee was first fully 7 executed. 8 Q. What does fully executing a franchise fee mean 9 in this situation? 10 A. For Blaine County, for which a franchise fee 11 is not applicable,2 and for the City of Ketchum, which 12 already has a franchise fee at the maximum rate of 3 13 percent, the Company would add an additional 3 percent 14 surcharge to the customers' bills. Ho wev er, for the City 15 o f Sun Valley, which has a franchise fee agreement that is 16 currently set at O percent, the Company requested that the 17 city raise its franchise fee to the ma x imum of 3 percent in 18 order t o collect its respective share of the total 19 incremental cost of the TP2 option. 2 0 Q. Did the Company c ommuni c at e these options to 2 1 the respective communities? 2 2 A. Yes. I have attached as Ex hibit No. 1 copies 2 3 o f three letters that Idaho Power sent t o the 2 4 jurisdi c tions, as well as to Commission Staff, on May 19, 2 Franchise fees are levied by municipalities ; therefore , it is not possible for Blaine County to implement a franchise fee . YOUNGBLOOD, DI 14 Idaho Power Company 1 August 5 , and Augus t 31 , 2016 . These letters evidence the 2 most recent outreach by Idaho Power to the jurisdictions in 3 an attempt to reach a compromise or consensus regarding the 4 redundant line into the North Valley . The May 19 , 2016 , 5 letter invites the jurisdictions to a "pre-filing 6 settlement conference " and states that prior to mak i ng a 7 formal filing with the IPUC that the Company would l i ke to 8 meet and update the parties regarding current routing 9 options and cost estimates and to discuss the parties ' 10 respective positions in anticipation of an eventual IPUC 11 filing . The parties met , in response to this letter , on 12 May 31 , 2016 . Whi l e the discussions were productive in 13 establishing a common understanding of the various 14 positions taken by the respective stakeholder groups , no 15 compromise was reached . 16 At the conclusion of the May 31 , 2016 , meeting , the 17 jurisdictions agreed t o conduct pub l ic meetings and 18 consider the route and cost options for the Hailey to 19 Ketchum redundant transmission line prior to the end of 20 August . Company representatives met again on August 3 , 21 2016 , with Sun Valley Mayor Peter Hendricks and staff , 22 Ketchum Mayor Nina Jones and staff , and Blaine County 23 Commissioner Lawrence Schoen and staff to answer any 24 additional questions or concerns . The Company also met 25 individually with a few of the larger customers in the area YOUNGBLOOD , DI 1 5 Idaho Power Company 1 who might be most impacted by a 3 percent surcharge, 2 including the Sun Valley Company and St. Luke's Hospital. 3 In the August 5, 2016, letter, Idaho Power 4 communicated the offer described above that outlined the 5 associated estimated cost of the three different overhead- 6 to-underground transition points and offered that the 7 Company would consider agreement to a surcharge option for 8 the incremental cost associated with TP2. On August 18, 9 2016, the Company attended and presented at a Ketchum town 10 hall meeting to inform the public of the need for the 11 redundant source of energy and the estimated costs of the 12 various options. 13 Q. What was the response to the Company's 14 proposed options detailed in Table l? 15 A. In general, the jurisdictions were 16 appreciative of the Company's consideration of alternative 17 funding arrangements. Specifically, there was 18 acknowledgement of the TPl option with no incremental costs 19 and the Company's willingness to recover the incremental 20 costs associated with TP2 through a surcharge. 21 Q. Do all the jurisdictions support the TPl 22 option? 23 A. The Company has not received formal 24 notification from any of the three jurisdictions in 25 opposition to the TPl option. In order to get a YOUNGBLOOD, DI 16 Idaho Power Company 1 confirmation of the positions of the individual 2 jurisdictions, the Company sent a letter on August 31, 3 2016, asking for a written indication of their preference 4 as to the routing and funding of the proposed line by no 5 later than September 23, 2016. The Company chose that date 6 because it provided each jurisdiction with an opportunity 7 to conduct at least one additional decision meeting prior 8 to providing a response back to the Company. In the 9 letter, the Company stressed that it believed the 10 Underground Transmission-TPl option appropriately balanced 11 the collective interests of the communities with the 12 Company's desire to continue to provide safe, reliable 13 electric service into the future. The Company requested 14 that the responses from the jurisdictions indicate their 15 support, or non-opposition to, the preferred construction 16 configuration (Underground Transmission-TPl). 17 Q. What response did the Company receive from the 18 individual jurisdictions? 19 A. On September 29, 2016, the Company received a 20 letter from the City of Sun Valley. In summary, the letter 21 stated that Sun Valley felt it was thoroughly informed on 22 the purpose and need for the redundant line, as well as the 23 impacts of potential routing options. Sun Valley stated 24 that at the regular City Council meeting of September 1, 25 2016, the Council unanimously agreed that the redundant YOUNGBLOOD, DI 17 Idaho Power Company 1 line project was necessary and vital for its community and 2 that the best location at which to underground the line 3 would be near the intersection of Highway 75 and Elkhorn 4 Road (the TPl option) . 5 Blaine County did not respond to the Company's 6 request by the September 23, 2016, deadline. The Company 7 had previously filed a request for a conditional use permit 8 ("CUP") which was before the Blaine County Planning and 9 Zoning Commission ("P&Z"). The P&Z did send out a notice 10 to the public, and to the members of the Wood River 11 Citizens' Advisory Committee and contributors to the Wood 12 River Electrical Plan, inviting them to a public hearing 13 held on October 13, 2016, where the details of the 14 transmission line project were discussed. Representatives 15 from the Company attended the meeting presenting details of 16 the overall project to the P&Z and answering questions from 17 the public. A second meeting was scheduled and held on 18 October 20, 2016, where the communication was just between 19 the P&Z and Idaho Power, enabling the Company to provide 20 very specific details on transmission lines versus 21 distribution lines, the benefits to Hailey area residents, 22 specifics on the construction process, and details of 23 structures and routes, etc. The Company updated the P&Z on 24 the CAC process, the need for the project, estimated costs 25 of the various alternatives, and took time to review the YOUNGBLOOD, DI 18 Idaho Power Company 1 route, comparing the existing facility infrastructure with 2 the proposed facilities . A final decision on the CUP is 3 scheduled for November 10 , 2016 . 4 Q. What response has the Company received from 5 the City of Ketchum? 6 A. While the Company has not received any 7 response from the city directly, Idaho Power is aware that 8 the City Council met on October 3 , 2016. At that meeting , 9 the Ketchum Energy Advisory Cornrni ttee ( "KEAC") recommended 10 that the City Council address its concerns to the IPUC and 11 request that Idaho Power be required to pay for an 12 independent cost-benefit and reliability analysis of 13 alternatives to a redundant transmission line. The KEAC 14 requested that in addition to evaluating local distributed 15 energy resource and microgrid options, that the city 16 request consideration of redundant distribution versus 17 transmission alternatives , which it believes , would allow 18 for local generation to integrate into the grid north of 19 the Hailey substation and move directly north , whereas, the 20 KEAC claims , redundant transmission does not. 21 Q. What is Idaho Power's conclusion from these 22 responses? 23 A. While the Company is aware of the concerns 24 raised by the City of Ketchum, the city's representatives 25 have not provided any viable alternative to the TPl option . YOUNGBLOOD , DI 19 Idaho Power Company 1 As discussed at length in Mr . Angell 's testimony , the 2 renewable and alternative solutions the City of Ketchum has 3 suggested are cost prohibitive , with implementation costs 4 much greater than the Company 's proposal . The City of Sun 5 Valley, as well as many other stakeholders in Blaine 6 County, have communicated with the Company that they are 7 supportive of the TPl option and understand that the 8 redundant line is needed and necessary for the Company to 9 continue providing reliable electric service to the North 10 Valley . The Company 's conclusion is that the TPl option 11 strikes a reasonable balance between project costs and the 12 goals of minimizing visual impacts . The Company believes 13 that the TPl option appropriately balances the collective 14 interests of the North Valley communities and stakehol ders 15 with the Company 's desire and obligation to continue to 16 provide safe , reliable electric service into the future. 17 Q. Has the Company received any other input from 18 community members regarding the August 5 , 2016 , proposal? 19 A. Yes . Since the May meeting , a number of 20 stakeholders from the jurisdictions expressed a preference 21 for TPl , the Elkhorn Road underground transmission line 22 option , with zero incremental costs above the economic base 23 case and no need for additional local funding . The TPl 24 option appears to strike a reasonable balance between the 25 YOUNGBLOOD , DI 20 Idaho Power Company 1 overall project cost and the goal of minimizing adverse 2 visual impacts for the North Valley area. 3 4 Q. III. REQUEST SUMMARY Please provide a summary of the Company 's 5 request . 6 A. Idaho Power serves over 9 ,100 customers in the 7 North Valley with a winter peak load of more than 60 MW. 8 Electricity for the North Valley area is supplied by a 9 single , 12 .4 mile , 138 kV transmission line constructed in 10 1962 with wooden towers . Access to repair the line is 11 impeded by residential development . Rough and mountainous 12 terrain that limits vehicle access impedes equipment set-up 13 and contributes to avalanche threats, all of which results 14 in extended repair times . The existing line's access 15 limitations are likely to result in sustained outages, with 16 the potential for an extended outage being catastrophic, 17 not only from the economic loss of the area , but the 18 additional damage that may be caused by water pipes 19 freezing. It is estimated that reconstruction of the 20 current line to replace existing wood structures with steel 21 structures would require numerous eight -hour line outages, 22 with the replacement of the line conductor requiring a six 23 to 12-week continuous outage . Another source of 24 electricity to serve the customers of the Ketchum and 25 YOUNGBLOOD , DI 21 Idaho Power Company 1 Elkhorn substations would be required during the 2 reconstruction period. 3 The Company has worked collaboratively for more than 4 a decade with the Wood River CAC to develop the Wood River 5 Valley Electrical Plan ("WREP"), a comprehensive plan for 6 future transmission facilities in the Wood River Valley, 7 including the North Valley area. The result was a plan 8 that recommended Idaho Power move forward with a series of 9 projects, including: (1) construction of a North Valley 10 project and (2) construction of a third 138 kV line in the 11 south valley. The Company is in the process of 12 constructing the south valley portion of the overa l l plan, 13 with the planned completion date in 2017. 14 The North Valley area presents a number of 15 challenges for the Company's traditional practices for 16 providing customers reliable electric service. 17 Traditionally, the Company would reduce the likelihood of 18 sustained outages by constructing multiple transmission 19 lines or implementing distribution circuits with tie 20 switches. But the North Valley is congested due to 21 numerous residences and businesses sited in a valley which 22 is less than one mile wide with mountains of steep slopes 23 and narrow roadways. In addition, the cities in the valley 24 have approved ordinances limiting development along the 25 mountains and restricting certain development for aesthetic YOUNGBLOOD, DI 22 Idaho Power Company 1 reasons, requiring new electrical facilities in Ketchum and 2 Sun Valley to be located underground. 3 A number of redundant service options were proposed 4 by the WREP and analyzed by the Company, with the Overhead 5 Distribution base case being determined as the lowest-cost 6 viable option. The Overhead Distribution construction 7 configuration became the Company's economic base case at an 8 estimated cost of $30 million, based on conceptual design 9 level estimates, including a 30 percent contingency. 10 With constraints on overhead construction in the 11 Wood River Valley, the Company also considered the 12 Underground Transmission option with the overhead-to- 13 underground transition point being located near the 14 intersection of Elkhorn Road and Highway 75. The total 15 construction cost estimate for TPl option is also $30 16 million, making it an economic alternative to the Company's 17 base case. 18 The Company compared this economic base case to the 19 Underground Transmission construction configuration with 20 the TPl option, which is economically equivalent with an 21 estimated construction cost of $30 million. In comparison, 22 the TPl option will provide additional stability over time 23 as it would allow for future growth in customer demand. 24 The Underground Transmission construction configuration 25 would provide full redundant capacity of the existing 138 YOUNGBLOOD, DI 23 Idaho Power Company 1 kV transmission line and would support a build-out demand 2 in the North Valley area of 120 MW. The line would provide 3 the ability to de-energize any section of either 4 transmission line for maintenance, inspection, repair, or 5 reconstruction, without customer interruption. The TPl 6 option appears to strike a reasonable balance between the 7 overall project cost and the goal of minimizing adverse 8 visual impacts for the North Valley area. 9 The Company has two compelling reasons that now 10 require the construction of this 138 kV transmission line: 11 (1) the increased reliability provided by the redundant 12 source of energy and (2) the need to reconstruct the 13 existing and aging 138 kV radial transmission line without 14 long-term disruption of service to the North Valley. The 15 Company has demonstrated the need for the redundant line, 16 has worked collaboratively with the North Valley community, 17 evaluated numerous alternatives to the viable solutions, 18 and has concluded with an economic alternative to the 19 lowest-cost option. 20 Q. What is the Company specifically requesting 21 the Commission provide? 22 23 A. Idaho Power respectfully requests that the Commission issue an order: (l)specifically finding that 24 the present and future public convenience and necessity 25 requires the construction of a new 138 kV transmission line YOUNGBLOOD, DI 24 Idaho Power Company 1 and related facilities to provide redundant service from 2 the Wood River substation, near Hailey, into the Ketchum 3 substation and (2) specifically granting the Company a 4 Certificate of Public Convenience and Necessity for the 5 construction of such line and facilities identified herein 6 as Underground Transmission-TPl. 7 Q. Is the Company, at this time, requesting a 8 rate adjustment for recovery of the construction cost 9 estimate of $30 million for the TPl option? 10 A. No, the Company is not seeking any specific 11 rate recovery for the facilities involved herein at this 12 time, and will do so in a proper rate recovery proceeding 13 in the future. 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. Does this conclude your testimony? Yes, it does. YOUNGBLOOD, DI 25 Idaho Power Company 1 ATTESTATION OF TESTIMONY 2 3 STATE OF IDAHO 4 ss. 5 County of Ada 6 7 I, Michael J. Youngblood, having been duly sworn to 8 testify truthfully, and based upon my personal knowledge, 9 state the following: 10 I am employed by Idaho Power Company as the Manager 11 of Regulatory Projects in the Regulatory Affairs Department 12 and am competent to be a witness in this proceeding. 13 I declare under penalty of perjury of the laws of 14 the state of Idaho that the foregoing pre-filed testimony 15 and exhibit are true and correct to the best of my 16 information and belief. ,,.,, 17 DATED this ~ day of November 2016. 18 19 20 21 22 SUBSCRIBED 23 November 2016. 24 25 26 27 28 29 this )) th day of S, Notary Public Residing at: Boise, Idaho My commission expires: 02/04/2021 YOUNGBLOOD, DI 26 Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-16-28 IDAHO POWER COMPANY YOUNGBLOOD, DI TESTIMONY EXHIBIT NO. 1 DONOVAN E. WALKER Lead Counsel dwalker@ldahopower.com May 19, 2016 VIA E-MAIL ONLY Jill S. Holinka Moore Smith Buxton & Turcke Legal Counsel, City of Ketchum 950 West Bannock Street, Suite 520 Boise, Idaho 83702 jsh@msbtlaw.com Timothy K. Graves Chief Deputy, Blaine County Prosecuting Attorney's Office 219 1st Avenue South, Suite 201 Hailey, Idaho 83333 tgraves@co.blaine.id. us Frederick C. Allington Interim City Attorney City of Sun Valley 115 Second Avenue South Hailey, Idaho 83333 fcallington@gmail.com Donald L. Howell, II Lead Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 don. howell@puc.idaho.gov An ID"CORP company Nina Jones Mayor, City of Ketchum 480 East Avenue North P.O. Box 2315 Ketchum, Idaho 93340 mayorsoffice@ketchumidaho.org Lawrence Schoen Commissioner, Blaine County 219 1st Avenue South, Su ite 208 Hailey, Idaho 83333 lschoen@co.blaine.id. us Peter Hendricks Mayor, City of Sun Valley 81 Elkhorn Road P.O. Box 416 Sun Valley, Idaho 83353 phendricks@svidaho.org Randy Lobb Utilities Division Administrator Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 randy. lobb@puc.idaho.gov 1221 W. Idaho St. (83702) P.O. Box 70 Boise, ID 83707 Exhibit No. 1 Case No. IPC-E-16-28 M. Youngblood, IPC Page 1 of 10 Wood River Valley May 19, 2016 Page 2 of 3 Re: Settlement Conference Regarding the Construction and Funding of the Hailey to Ketchum Transmission Line Dear Parties: Idaho Power Company ("Idaho Power") would like all parties to attend a formal settlement conference to attempt to reach resolution regarding the siting, construction , and funding of the planned secondary source for energy delivery to the northern portion of the Wood River Valley ("North Valley"). Idaho Power proposes this settlement conference be held on May 31, 2016. This is the first available date that the required Idaho Power personnel are available. I hope this date is workable for everyone. If not, please contact me directly so that we can adjust the date to accommodate schedules. Idaho Power would be happy to host the settlement conference either at its corporate headquarters in Boise, at its Hailey Operations Center, or at any other location most convenient to the parties. For the past 30 years there has been an increasing need to improve the reliability and quality of service provided by the current transmission line into. the North Valley, between Hailey and Ketchum. At this conference we have an opportunity to come together and resolve the remaining issues regarding the line prior to any filings with the Idaho Public Utilities Commission ("IPUC"). Below I provide some background on the present situation. Idaho Power has spoken and worked with you and/or your respective organizations about the need to construct a secondary source for electric energy to serve the needs of Idaho Power customers in the North Valley. In the simplest terms, the entire North Valley (City of Ketchum, City of Sun Valley, and Blaine County) has been and is currently served by a single source of energy, a radial, 138 kilovolt ("kV") transmission line that connects the Wood River substation, near Hailey, to the Elkhorn and Ketchum substations. This existing line was constructed in 1962 with wood structures. There have been a number of reliability events and concerns with the aging line, and Idaho Power projects significant outages and interruptions of service going forward. The line must be reconstructed. More importantly, to truly improve the reliability and quality of service to the North Valley, a second, independent source for energy-a second 138 kV transmission line­ is required. The second line has been needed and in various stages of planning for approximately 30 years. For various reasons, primary of which is lack of agreement upon siting a new line and the visual impacts of such, Idaho Power has been unable to site and construct this second line into the North Valley. Idaho Power has conducted two Community Advisory Committee ("CAC") proceedings, and various other community outreach efforts regarding a proposed second transmission line. The result of the CAC processes was a recommendation to construct the new 138 kV line overhead, generally along the highway from Hailey until just south of the St. Luke's Medical Center, and then underground through Ketchum to the Ketchum substation. Idaho Power has submitted permit applications for this route. Exhibit No. 1 Case No. IPC-E-16-28 M. Youngblood, IPC Page 2 of 10 Wood River Valley May 19, 2016 Page 3 of 3 However, the undergrounding of 138 kV transmission facilities is more expensive than standard overhead construction. Because overhead construction costs less and provides the required reliability and service quality improvements, the cost differential resulting from the local requirement to underground the facilities must be borne by the local beneficiaries of such undergrounding, and not by the entire body of Idaho Power customers. In our last discussions of cost allocation and payment for this incremental cost difference, it appeared that the City of Sun Valley and Blaine County were willing to pay their allocated portion. The City of Ketchum requested that Idaho Power include its allocation as a surcharge for collection on Idaho Power's electric bills. Idaho Power does not agree that this is appropriate, and Ketchum's response is that it would like to hear from the IPUC on the matter before considering any other options. Since that time , Idaho Power has prepared a draft filing to bring this matter to the IPUC for determination. Idaho Power, as referenced above, has also continued to seek the necessary permits for the line, and to refine the possible route configurations and cost estimates. Prior to making a formal filling with the IPUC, Idaho Power would like affected parties to come together for a formal, pre-filing settlement conference. Idaho Power would like to update all parties with regard to current routing and cost estimates, as well as discuss the draft IPUC filing, and what that process entails. IPUC Staff has been invited to this settlement conference to offer its view and position on the issues. Most importantly, it appears that the parties are close to being able to resolve the issues and solve a long-term and continuing problem that will only get worse if left unattended. A representative for each entity that has authority to negotiate and make decisions should attend the settlement conference with its own legal counsel , it being understood that any agreements reached may need some further action for approval. Please let me know at your earliest convenience if you are able to attend a conference on May 31 , 2016, and your preference for where the conference should be held. I look forward to hearing back from you and hopefully working to a mutually agreeable resolution . Sincerely, ~z.w~ Donovan E. Walker Lead Counsel, Idaho Power Company DEW:csb Exhibit No. 1 Case No. IPC-E-16-28 M. Youngblood, IPC Page 3 of 10 ; DONOVAN E. WALKER Lead Counsel dwalker@idahopower.com August 31, 2016 VIA E-MAIL ONLY Jill S. Holinka Moore Smith Buxton & Turcke Legal Counsel, City of Ketchum 950 West Bannock Street, Suite 520 Boise, Idaho 83702 jsh@msbtlaw.com Timothy K. Graves Chief Deputy, Blaine County Prosecuting Attorney's Office 219 1st Avenue South, Suite 201 Hailey, Idaho 83333 tgraves@co.blaine.id.us Frederick C. Allington Interim City Attorney City of Sun Valley 115 Second Avenue South Hailey, Idaho 83333 fcallington@gmail .com Karl T. Klein Deputy Attorney General Idaho Public Utilities Commission 4 72 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 karl.klein@puc.idaho.gov An IDACORP Company Nina Jones Mayor, City of Ketchum 480 East Avenue North P.O. Box 2315 Ketchum, Idaho 93340 mayorsoffice@ketchumidaho.org Lawrence Schoen Commissioner, Blaine County 219 1st Avenue South, Suite 208 Hailey, Idaho 83333 lschoen@co.blaine.id.us Peter Hendricks Mayor, City of Sun Valley 81 Elkhorn Road P.O. Box 416 Sun Valley, Idaho 83353 phendricks@svidaho.org Randy Lobb Utilities Division Administrator Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 randy.lobb@puc.idaho.gov 1221 W. Idaho St. (83702) P.O. Box 70 Exhibit No. 1 Boise, ID 83707 Case No. IPC-E-16-28 M. Youngblood, IPC Page 4 of 10 Wood River Valley August 31, 2016 Page 2 of 3 Re: Construction and Funding of the Hailey to Ketchum Transmission Line - Follow-up after Public Meetings Dear Parties: When we met on May 31 5\ the jurisdictions agreed to conduct public meetings and consider the route and cost options for the Hailey to Ketchum Redundant Transmission Line prior to the end of August. Thank you for conducting your public meetings in that timeframe and for allowing Idaho Power's participation in the same. As we discussed in May, the purpose of these discussions is to see if we could reach agreement on a proposal to present to the Idaho Public Utilities Commission (IPUC) as part of a request for a Certificate of Public Convenience and Necessity related to construction of the redundant line. The purpose of my letter today is to ask for a written indication of your preference as to the routing and funding of the proposed line by no later than September 23, 2016. This chosen date provides each jurisdiction with an opportunity to conduct at least one decision meeting prior to issuing a response to this request. Since our May meeting, a number of stakeholders from the jurisdictions have expressed a preference for the Elkhorn Road underground transmission line option with zero incremental cost and no local funding requirement. The Elkhorn Road underground transmission line option appears to strike a reasonable balance between cost and minimizing visual impacts. We have discussed this option with representatives from the Sun Valley Water and Sewer District, St. Luke's Wood River Medical Center, and Idaho Transportation Department, and based on those discussions, the option appears feasible. Idaho Power believes that the Elkhorn Road underground transmission line option appropriately balances the collective interests of your communities with our company's desire to continue to provide safe, reliable electric service into the future . Based on that view, Idaho Power's preference is to move forward in pursuit of that construction configuration. We ask that you respond by September 23, 2016, and hope that your response will indicate support, or non-opposition to, this preferred construction configuration. As discussed previously, Idaho Power intends to make a filing with the IPUC by the end of September/beginning of October and sincerely hopes that we can jointly recommend an option to the IPUC. If there are any comments, questions, or issues please feel free to contact me directly. Thank you for your time and consideration , and I look forward to hearing back from you soon. Exhibit No. 1 Case No. IPC-E-16-28 M. Youngblood, IPC Page 5 of 10 Wood River Valley August 31, 2016 Page 3 of 3 Sincerely, ~Z.u)~ Donovan E. Walker Lead Counsel, Idaho Power Company Exhibit No. 1 Case No. IPC-E-16-28 M. Youngblood, IPC Page 6 of 10 , Hailey to Ketchum Transmission Line Transition Structure Location Options August 2016 Options: 1 : Elkhorn Road 2: Hospital Drive 3: Owl Rock Road - - - -Overhead Transmission - - - -Underground Transmission * Transition Location Varies Exhibit No. 1 Case No. IPC-E-16-28 M. Youngblood, IPC Page 7 of 10 DONOVAN E. WALKER Lead Counsel dwalker@idahopower.com August 5, 2016 VIA E-MAIL ONLY Jill S. Holinka Moore Smith Buxton & Turcke Legal Counsel, City of Ketchum 950 West Bannock Street, Suite 520 Boise, Idaho 83702 jsh@msbtlaw.com Timothy K. Graves Chief Deputy, Blaine County Prosecuting Attorney's Office 219 1st Avenue South, Suite 201 Hailey, Idaho 83333 tgraves@co.blaine.id. us Frederick C. Allington Interim City Attorney City of Sun Valley 115 Second Avenue South Hailey, Idaho 83333 fcallington@gmail.com Karl T. Klein Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 karl. klein@puc.idaho.gov An IDACORP Company Nina Jones Mayor, City of Ketchum 480 East Avenue North P.O. Box 2315 Ketchum, Idaho 93340 mayorsoffice@ketchumidaho.org Lawrence Schoen Commissioner, Blaine County 219 1st Avenue South, Suite 208 Hailey, Idaho 83333 lschoen@co.blaine.id.us Peter Hendricks Mayor, City of Sun Valley 81 Elkhorn Road P.O. Box416 Sun Valley, Idaho 83353 phendricks@svidaho.org Randy Lobb Utilities Division Administrator Idaho Public Utilities Commission 4 72 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 randy. lobb@puc.idaho.gov 1221 W. Idaho St. (83702) P.O. Box 70 Exhibit No. 1 Boise, ID 83707 Case No. IPC-E-16-28 M. Youngblood, IPC Page 8 of 10 Wood River Valley August 5, 2016 Page 2 of 3 Re: Construction and Funding of the Hailey to Ketchum Transmission Line - Follow-up to May 31, 2016, Meeting Dear Parties: Thank you for meeting with us and Mr. Howell, representing the Idaho Public Utility Commission ("IPUC") Staff, on May 31 to discuss the Hailey to Ketchum Redundant Transmission Line. We at Idaho Power remain concerned about the reliability of electric service to the Wood River Valley, north of East Fork Road, and believe a second transmission line is necessary to reduce the risk of extended outages. We appreciate the jurisdictions' commitment to bring the options we discussed to the public and to identify community preferred options for location and funding by the end of August. Idaho Power is committed to providing support during your public meetings. During our discussions regarding funding options for the jurisdictions, including at the May 31, 2016, meeting, the City of Ketchum requested that Idaho Power include Ketchum's allocation of incremental cost difference as a surcharge for collection on Idaho Power's electric bills. Idaho Power has stated that a surcharge is not a suitable solution. Ketchum's response has been that it would like to hear from the IPUC on the matter before considering any other options. Because of the unique circumstances presented in the North Valley, and because we are now so close to solving this long term problem, in the hope that we can reach agreement with the jurisdictions as to funding, Idaho Power has reconsidered its position regarding a surcharge. The Company has heard and understands the requests for a surcharge, and after much further deliberation would be willing to agree, under certain circumstances, to a surcharge funding option. Idaho Power wishes to communicate this information to the jurisdictions, and to clarify the current options in advance of the public meetings. There are currently three options for locating the transition from overhead to underground: (1) Elkhorn Road -This option is the northernmost option and would have no incremental cost difference from the typical overhead construction solution. Consequently, there would be no local funding requirement with this option; (2) Hospital Drive -This option would locate the transition from overhead to underground directly near the intersection of Hospital Drive and State Highway 75. It would contain an incremental cost above the typical overhead solution of approximately $2.6 million. Idaho Power would agree that the City of Ketchum and Blaine County could implement a 3% surcharge for approximately 10 years to collect this amount plus cost of financing, and the City of Sun Valley could implement a 3% franchise fee to accomplish the same; (3) Owl Rock Road -This is the current southernmost option for the overhead to Exhibit No. 1 Case No. IPC-E-16-28 M. Youngblood, IPC Page 9 of 10 Wood River Valley August 5, 2016 Page 3 of 3 underground transition and has an estimated incremental cost above the typical overhead solution of approximately $5.5 million. This amount is too large for Idaho Power to agree to a surcharge option and each jurisdiction could implement a Local Improvement District ("LID") to collect the amount. These funding options are summarized in the following table: Underground Total Cost Incremental Collection Method Surcharge Transition Location Estimate* Cost* Rate/Du ration Option 1 -$30.0M $0 N/A N/A Elkhorn Road Option 2-$32.6M $2.6M Surcharge and 3%/-10 years Hospital Drive (excluding Franchise Fee financing cost) Option 3-$35.5M $5.5M LID Owl Rock Road *The costs are based on conceptual level design estimates provided by a third party engineer and may increase or decrease as the final design is refined . Variances may result from securing right-of-way and identifying unique construction conditions. Idaho Power looks forward to working with you at your upcoming public meetings, and sincerely hopes that we can jointly recommend one of the above three options, along with the jurisdictions, to the IPUC in a September or October filing. Sincerely, ~Z.td~ Donovan E. Walker Lead Counsel, Idaho Power Company Attachment: Map Exhibit No. 1 Case No. IPC-E-16-28 M. Youngblood, IPC Page 10 of 10