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HomeMy WebLinkAbout20170623Porter Rebuttal.pdfAn IDACORP Company DONOVAN E. WALKER Lead Counse! dwal ker@idahopower. com June 23,2017 VIA HAND DELIVERY Diane M. Hanian, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, ldaho 83702 Re: Case No. IPC-E-16-28 Certificate of Public Convenience and Necessity for Wood River Valley ldaho Power Company's Rebuttal Testimony Dear Ms. Hanian Enclosed for filing in the above matter are an original and eight (8) copies each of the RebuttalTestimony of N. Vern Porter and the Rebuttal Testimony of David M. Angell. One copy of each of the aforementioned testimonies has been designated as the "Reporter's Copy." ln addition, a disk containing Word versions of the testimonies is enclosed for the Reporter. Very truly yours, It-;SEffi*. ?ild!/\- ':-t., .l Donovan E. Walker DEW:csb Enclosures 1221 W. ldaho 5t. (83702) PO. Box 70 Boise, lD 83707 BEFORE THE TDAHO PUBLIC UTILTTIES COMMISSION IN THE MATTER OE THE APPLICATION OF IDAHO POWER COMPANY FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE WOOD RIVER VALLEY IDAHO POWER COMPANY REBUTTAL TESTIMONY OF N. VERN PORTER CASE NO. ]PC-E-16-28 1 2 3 4 5 6 7 I 9 O. Please state your name and business address. A. My name is N. Vern Porter and my business address is 7221 West Idaho Street, Boise, Idaho 83102. O. By whom are you employed and in what capacity? A. I am employed by Idaho Power Company ("Idaho Power" or "Company") as the Vice President of Transmission and Distribution Engineering and Construction and Chief Safety Officer. Pl-ease descri-be your educational- background. of Brigham Young University of Science in electrical-where I received my engineering in 1985 o A10 Iama graduate Bachelort_ t_ L2 13 L4 15 and Master of Sci-ence in 1986. I also received my from Boise o. Executive Master of Business Administration State University in 20L3. Pl-ease describe your work experience with L6 Idaho Power. L7 A. I joined Idaho 18 career in 1986 with Pacific 79 20 21, 22 23 24 25 Power in 1989 after starting my Gas and Blectric Company. I have held a variety of positions within Idaho Power, incl-udinq high voltage transmission engineer, system planner, technical operations engineer, energy trader, senior manager of grid operations, senior manager of customer service, and general manager of power production. In October 2009, I was named Vice President of Delivery Engineering and Construction. PORTER, REB Idaho Power 1 Company 1 2 3 4 5 6 1 I 9 fn December 20L3t T was appointed to l-ead a Company- wide safety initiative to transform the safety cul-ture and work with all business units to j-mprove safety for employees and the public. In April 2015, I became the Vice President of Customer Operations, a position I hel-d until- my current position. On March \, 2011 , I assumed the rol-e of Vice President of Transmission and Distribution Engineering and Construction and Chief Safety Officer for Idaho Power. O. What is the purpose of your rebuttal testimony in this matter? A. The purpose of my rebuttal testimony is to respond to issues addressed in the direct testimony of the other parties to this case, particularly those of Idaho Pub]ic Utilities Commission Staff ("Staff") witness Michael Morrison. I will generally address three main areas in my testimony: (1) the significance and necessity of the Idaho Public Utilities Commission's ("Commission") determination regarding the North VaIley obligation to 10 11 72 13 74 15 16 t7 1B 19 20 23 need to provide a in order for Idaho redundant l-ine into the Power to meet its 21,reliably serve the public; (2) the need to kil-ovolt ("kV") transmission22 reconstruct the existing 138 24 line currentl-y serving the North Va11ey; and (3) the appropriate base case line route and configuration from which any potential additional incremental- cost is25 PORTER, REB 2 Idaho Power Company 1 2 3 4 5 6 7 8 9 cal-culated and allocated to the local jurisdictions, if the Commission determines a redundant line to be required. I will discuss the multiple factors Idaho Power considered when determining the need for the redundant transmission line for the North Valley and discuss j-ssues and concerns that were considered when choosing the proposed route and request for a Certifi-cate of Pub1ic Convenj-ence and Necessity (*CPCN") . I. RELIABLE UTTLITY SERVICE O. From your perspective, what is the primary j-ssue or problem the Company is trying to address and sol-ve when proposing to construct a redundant 138 kV transmission fine from the Wood River substation, near Hailey, to the Ketchum substation? A. The primary i-ssue is reliability of el-ectric service. A long-term power outage caused by the l-oss of the single transmissj-on line serving the North VaJ-1ey, particularly during extreme weather conditions, poses a risk to the community that Idaho Power bel-ieves should be addressed. After considering all avail-abl-e opti-ons to provide adequate reliability, the Company has proposed building a redundant transmission l-ine as the most cost effective and viable solution to address this reliability issue. This is consistent with how fdaho Power has planned, designed, constructed, and operated its system 10 11 L2 13 L4 1trJ-J 1,6 !1 18 L9 20 2t 22 23 24 25 PORTER, REB fdaho Power 3 Company 1 across its service territory, and is consistent with the 2 prudent e.l-ectric utility design, planning, and system 3 configuration of many other utilities. Idaho Power witness 4 David M. AngeII, Transmission and Distribution Planning 5 Managar, will- further discuss the Company's planning 6 process and util-ity practices in his rebuttal testimony. 1 Q. Have you reviewed the testimony provided by B Staff witness Michael- Morri-son? 9 A. Yes. Mr. Morrj-son u1timately concludes that 10 there is no demonstrated need for a redundant arguing that the existing radial- reliable on its own and that it provide redundant facilities. Is this consistent with prudent 1ine, 11 L2 utility t-5 essentially suf f icj-entIy expensive to o. practices of l-ine is is too 13 L4 76 L1 1B L9 20 21 22 23 24 expected of service to its provision of reliability essential the public? A. No, Idaho Power designs its system to meet certain reliabil-ity and service quality standards. When certain criteria are met, redundant service is provided to reduce the risk, cost, and potential damage to the public from interruption of service or long-term outage. The North Va11ey area has grown to such a size, is relatively remote with difficul-t access to facilities, and has a substantial seasonal- resort economy-that the risk of harm system design the Company in and the level of PORTER, REB Idaho Power 4 Company 25 1 2 3 4 5 6 7 8 9 from a potential long-term outage and the potential catastrophic effects of a long-term outage during extreme winter conditions when North Val1ey electric l-oad peaks is be served by a single, radial- feed-no matter 10 too great to how reliable the past. o. considered if to serve the A. provided by Wood River that sj-ngIe transmj-ssion l-ine may have been in What are some of the risks the Company has transmi-ssion l-ineit were to rely on just one North Va1ley? The North ValIey's electrical- supply is the L2.4 mi-l-e transmi-ssion line between the substation and Ketchum substation. If the line 11 L2 13 has a problem that resul-ts in an outage, the North Va11ey 1,4 residents and businesses wil-I l-ose power until the l-ine is 15 restored. Portj-ons of the line are in rough terrain and 76 difficult to access, especially during the winter. If the t7 l-ine were to fail- in one of these difficult access areas 18 during the winter, it could take several- days or weeks to 19 restore electric service, jeopardizing public safety, 20 essential services, businesses, and increasing the 27 potential for extensive property damage. It is not a 22 question of tf, but when some event (ice loading, 23 avalanche, high winds, fire, etc. ) w111 take the line out 24 of service and the North Valley wil-l be without power for 25 multiple days. An event similar to this described scenario PORTER, REB 5 Idaho Power Company 1 2 3 4 5 6 1 o 9 unfolded earli-er this year in Jackson HoIe, Wyoming. In February, heavy snow and strong winds toppled 71 steel power poles supporting the single transmission l-ine supplying the resort and local area. Below i-s a photograph showing some of the downed structures. 10 11 :#rs.**I 72 13 74 15 76 71 1B 79 20 2t 22 23 24 a '1 I It took five days to restore power. Keep in mind that the 1,7 poles were easily accessible on flat terraln as they were directly adjacent to the maj-n road to the Jackson Hole resort, not up 1n the mountains, dS is the case with portions of Idaho Power's transmission Iine servi-ng the North Va11ey. The outage dlsrupted vacation plans and closed snow-dependent businesses during one of the area's busiest months. PORTER, REB fdaho Power 6 Company 25 1 2 3 4 5 6 7 8 9 O. Have other communities taken comparable reliabil-ity measures in constructing redundant transmission service ? A. Yes. Reliability concerns are not new or unique to Idaho Power. Idaho Power has installed redundant transmission l-ines to other mountain communi-ties that have faced similar issues to provide adequate servj-ce to residents and businesses. In McCall, for example, historical-1y, the loss of its single 138 kV transmission Iine serving the area during high l-oad periods resulted in rotating outages. Idaho Power successfully worked with the city and others to construct a second 138 kV line to the McCaIl substation. Now that community enjoys a significant 10 11 72 13 L4 boost in reliabil-ity that supports future economic growth 15 and the safety of the public. !6 Examples of other area resort-based communities that L7 are somewhat similarly situated as the North VaIIey and 18 have built redundant transmission l-ines to support reliable L9 utility service are: 20 o Vail, Colorado-served by redundant 115 kV 2l l-i-nes. 22 . Aspen, Colorado-served by redundant 115 kV 23 lines. 24 o Park City, Utah-served by two 138 kV l-ines 25 and a sJ-ngle 46 kV line. Rocky Mountain Power is not PORTER, REB Idaho Power 7 Company 1 2 3 4 6 6 7 B Y capabl-e of serving the entire load after the loss of one 138 kV l-ine and is planning to buil-d an additional 138 kV l-ine to Park City. O. Why does the Company believe that it is necessary to file for a CPCN at this time? A. After the 2009 Christmas outage, where Wood River customers were out of power between approximately 1-1 to 21 hours, Idaho Power met with citizens, businesses, and city and county leaders. The Company committed that it would move forward on two transmission projects identified in the 2007 Wood River Electrical- Plan to improve reliability in the area: 1. Reinforce the transmission service to Ir'Iood River substation; and 2. Build a redundant line between Wood River-Ketchum. V0ith respect to the first commitment, Idaho Power will- complete the rebuild of the King to Wood River 138 kV Iine j-n 2071 (originally built in 7962, as was the Wood River to Ketchum line). The Company has been abl-e to rebuil-d the King to Wood River l-ine with the l-ine de- energj-zed due to the existence of a second transmission line serving the Wood River substation. This has resulted in cost savlngs, improved reliability, and enhanced safety for workers during the rebuil-d process when compared to PORTER, REB Idaho Power B Company 10 11 72 13 L4 15 16 L7 18 79 20 2L 22 23 24 25 1 2 3 4 5 6 7 I 9 trying to rebuil-d the l-ine while energized. This is the exact same de-energized ability and benefits that would be avail-abl-e when rebuil-dlng the existi-ng Wood River-Ketchum line if the proposed redundant Wood River-Ketchum l-ine is in pIace. With respect to the second commitment, Idaho Power has worked with the Community Advisory Committee ("CAC"), community leaders, businesses, residences, etc., to develop a practical solution that woul-d provide additional safety and security to the North Va11ey. Idaho Power has looked at other alternatives (e.9., so1ar, storage, diesels), but the redundant l-ine is the least expensive and most viable alternative to provide adequate reliability for al-l- North Val1ey customers. After all the discussions, meetings, open houses, and many varying opinions, it is time that a decision is made on the l-evel of reliabil-ity that ldaho Power is required to provide its customers in the North Wood Rj-ver Valley. One of the reasons for filing for this CPCN is to get the stakehol-ders together and have the Commission make a decision about whether the Company's obligation to reliably serve as a public utility requires the construction of a redundant transmission l-ine to the North VaIley. 10 11 L2 1_3 L4 15 76 t7 18 79 20 2L 22 23 24 PORTER, REB Idaho Power 9 Company 25 1 2 3 4 5 6 7 I 9 Idaho Power believes that, consistent with the prudent planning, design, construction, and operation of its entire system, its obligation to reliably serve as a public utility requires the construction of a redundant transmission l1ne to the North Val-Iey. While there are several parties that disagree with this fundamental- determination, there are al-so numerous parties that desire and support the construction Commission determi-nes that a of a redundant line. If the redundant 10 there are 11 significant issues related and cost responsibility for w111 discuss later 1n my the the issue that situation in North redundant transmission line is required, the configuration,to routi-ng, which I that redundant 1ine, testimony. However, there Commission must resolve: Val1ey require the line in order to L2 13 t4 15 \6 L7 18 19 20 27 22 23 24 is this threshold Does the present construction of a mitigate the risk to public safety, essential- services, businesses, and property damage posed by an extended outage of the current radial- transmission service and for Idaho Power to meet its obligati-on to reliably serve that portion of the public? Idaho Power, the CAC, as wel-l- as varj-ous businesses and members of the North Va1ley community, bel-ieve that a long-term power outage caused by the l-oss of the single transmission line servj-ng the North Valley during extreme weather conditions poses a risk to the PORTER, REB fdaho Power 10 Company 25 1 2 3 4 5 6 7 8 9 community that is unacceptabl-e and requires construction of a redundant transmission l-ine as proposed. II. RECONSTRUCTION OF THE EXISTING LII{E O. Are there any problems with the existing line? A. The existing transmission line, while historically performing very wel-1, is aging and needs to be rebuilt. It was buil-t in 7962 and passes through mountainous areas that are extremely difficult to access, particularly in the winter months. It is worthy of note that Idaho Power has maintained the line well, resulting i-n few outages. However, this wood-pole transmj-ssion l-ine is aging and the risk of fail-ure is increasj-ng-driving the need to take actj-on. Several- structures have been severely damaged by woodpeckers and some have been replaced. It is a mistake to assume that because the l-j-ne has performed weII in the past that it wiII continue to do so, especially 10 11 12 13 74 15 t6 l1 as it ages. 18 As the line ages, the probability of fai1ure will 19 increase and therefore the Company must rebuild the 20 existing line. It is important to note that the rebuild of 27 the existing line is an independent j-ssue and does not 22 alleviate the need to build a redundant line. The rebuil-t 23 line will provide a "reset" on the strength and capability 24 of the existing l-ine; however, the North Valley would sti1l 25 be exposed to the risk and lmpacts of losing that single PORTER, REB Idaho Power 11 Company 1 2 3 4 5 6 1 8 9 line. In other words, the existing line will- need to be rebuilt regardless of, and independent of, any determination as to the construction of a redundant l-ine. If the proposed redundant l-ine is authorized by the Commission and constructed by the Company, then the rebuild of the existing line can be coordinated with the redundant l-ine, and completed with little to no interruption of service in a much safer manner for work crews and the public. If the redundant line is not authorj-zed or constructed, the existing Iine wil-l- still need to be rebuil-t. A temporary line will- need to be constructed to 10 11 L2 provide service to the North Va11ey whil-e the 13 is rebuilt, This wou.l-d and then removed once construction existing line is complete. 74 result in significant waster ds the resources 15 used for the temporary line could al-ternatively be applied 76 to constructing a permanent redundant solutj-on. 17 O. Staff witness, Mr. Morrison, recommended that 18 the Commission direct the Company to install a temporary 19 overhead transmission line as necessary to faci-Iitate the 20 repair of the existing transmission l-ine. What issues do 27 you see with bullding a temporary transmission line and 22 then rebuilding the existing Wood River-Ketchum l-ine? 23 A. As I stated, and as Staff recognized, 24 regardless of the Commission's determination as to the 25 necessity of a redundant transmission l-ine, the existi-ng PORTER, REB Idaho Power L2 Company 1 2 3 4 5 6 7 U 9 l-ine wil-l- need to be rebuilt. The temporary line option suggested by Staff j-nvolves building a temporary 138 kV overhead transmisslon l-ine from Wood River to Ketchum 1n a route separate from the existing line. This l-ine would then be energi-zed whil-e the existing l-ine is rebuil-t. After construction is complete, the temporary line would be removed. It is estj-mated the "temporary" line will be in place for approximately two years. On the surface this may appear to be a simple viabl-e option, but severa1 prohibitive issues remain. First and foremost, Idaho Power's overall objective of achieving adequate rellability w1l-l not be achieved as there would still be a radial- l-ine (albeit new) serving the North Va11ey. The other prohibitive factor j-s the same routing barriers associated with routing a permanent overhead Iine through Blaine County and the city of Ketchum wil-l- be present when attempting to route the temporary line. Idaho Power vj-ews routing any overhead transmission line through the city of Ketchum, whether new or temporary, as not viabl-e for many of the same reasons a permanent overhead transmj-ssion l-ine is not a vj-abIe option. In addition, the temporary J-ine in the downtown Ketchum area could be nearly as costly as a permanent overhead l-iner ds self-supporting steel poles will be required due to street overhang and the numerous angles and turns required in the route. Fina11y, Idaho PORTER, REB Idaho Power 10 11 L2 13 L4 15 L6 \7 18 !9 20 2L 22 23 24 13 Company 25 1 Power expects the same legal challenges and delays to be 2 experienced as well-. 3 At the end of this process, and after great effort 4 and expense, the communities in the North Va11ey will be 5 l-eft in the same compromised reliabili-ty situatj-on as they 6 are today-exposed to the potential risk to public safety, 7 essential services, and business and property damage that 8 could result with the loss of the single, radial 9 transmission line. Rather than waste resources on a 10 temporary Iine that would be removed and salvaged, it makes 11 sense to apply these efforts and resources to a more L2 permanent and rel-i-able sol-ution for the the redundant transmission North Va11ey by fine.13 1,4 constructing rrr.APPROPRIATE BASE CASE FOR COST AILOCATION 15 O. Staff recommends that if the Commission 1,6 authori-zes the constructi-on of a redundant l-ine that it L1 "order the Company to consider the Overhead Transmission 18 route through downtown Ketchum as the base case for 19 determining the cost to be borne by the Company's general 20 body of rate payers, and that any additional costs of 27 undergrounding be funded 1oca11y. "1 Staff stated that "the 22 Company has explored Overhead Transmissj-on options that are 23 technically feasibl-e, and that may not require easements. 24 The Company rejected these options because of local- PORTER, REB Idaho Power L4 Company 1 Morrison Dlrect, p. 2'7. 1 aesthetic concerns."2 Further, Staff was critical- of the 2 Company for selecting the Overhead Distribution routing and 3 configuration as a base case stating, "the Company's 4 proposed base case appears to be an inadequate, non- 5 standard alternative used to justify the high cost of its 6 preferred route. "3 Does Idaho Power agree with Staff's 7 recommendation and comments regarding the appropriate base 8 case line route and configuration? 9 A. No. Staff appears to have inappropriately 10 focused upon aesthetic and visual- impact conslderations, 11 and makes l-ittl-e to no mention of the several other factors 72 that are considered in selecting an appropriate base case 13 scenarlo from which to measure potential- incrementaf cost L4 increases attributable to local- jurisdictions. Staff has 15 fail-ed to recognize any distinction with regard to an 16 overhead 138 kV transmj-ssion line routed through downtown 17 Ketchum in what is theoretically possible from an 18 engineering perspective and what is practj-caI, feasible, t9 and prudent to route, permj-t, construct, and operate. 20 The Company does not disagree with the general 27 principles set forth by Staff: That typically overhead 22 construction of transmissj-on lines is the lowest cost, most 23 predominant method of construction, and that typically 2 Morrison Direct, p 3 Morrison Direct, p 20 PORTER, REB Idaho Power 15 Company aa 1 2 3 4 5 6 7 I 9 municipalities or local jurisdlctions facil-ities to be l-ocated underground aesthetic reasons are responsible for that require for their own the incremental- cost difference between those facilities and However, this 1s or order. the cost of not mandated by There is no overhead construction. any partj-cular statute, irrebuttable presumpt j-on customers coul-d never be underground facil-ities . ru1e, that responsible Idaho Power Idaho Power's body of for the cost of frequently informs and 10 reminds local- municipal-ities and jurisdictions that such 11 local- requirements must be paid for by the l-ocal- customers LZ and jurisdictions that benefit from them, and cannot be l-3 passed on to the larger body of ldaho Power customers to 74 pay for. In fact, fdaho Power has informed North Va1ley 15 residents, specifically incl-udlng Ketchum, of this standard 76 and requirement. However, the situation here is different, \7 in particular, because an overhead 138 kV transmission l-ine 18 through downtown Ketchum j-s not a viable route. As 19 previously stated in the Company's Application, testimoDy, 20 and discovery responses, an overhead transmissj-on route 27 through downtown Ketchum is nelther practical nor feasible, 22 and because of this, it is not equitable to consider this 23 as a "base case" for cost determination. The least-cost, 24 viable option is the overhead distribution Company's selected base case of an configuration for cost25 PORTER, REB Idaho Power \6 Company 1 2 3 4 5 6 1 I 9 determinations. The Company's reconrmended route, that includes underground transmission through the city of Ketchum is cost equj-valent to the lowest cost base case of overhead distribution, but requj-res extending the overhead transmission portion further north than recommended by the CAC. It is important to note that the the Company's more typical miles of the Company' s Underground Transmission-TP1 option 11 is overhead 138 kV transmlssion l-ine from the Wood River 12 substation to just outside of the city of 10 proposed redundant line is overhead line construction. the last two miles into the great majority of comprised of the The initial 9.2 Ketchum, where configuration for Ketchum 13 numerous constraints require a different 74 15 t6 L1 22 23 approximately substation. a. final- portion simply to Ketchum. "a Could the Company's proposal to construct the of the 138 kV redundant transmission l-ine 18 underground be considered "special treatment" for the L9 Ketchum community? 20 Staff was critical ofA the Company, accusing and unnecessary cost27 Idaho Power of incurring additional provi-de "aesthetic benefits to the City of 24 irrelevant, Staff implies that aesthetic consj-derations are improper, and inappropriate to even mention, PORTER, REB 11 Idaho Power Company a Morrison Direct, pp. 3, 15, 20 1 2 3 4 5 6 7 I 9 which is not the case. not irrelevant and is doing for the City of always considers when other considerations. The Company's proposal is a combination overhead and underground 138 kV transmj-ssj-on project and is the result of collaboration with the CAC, customers, and city and county l-eaders. Routing a transmission line through cities and towns is complex and there is definitely not a "one- size-fits-al-l-" approach. When routing a new transmission line, whether in Ketchum or anywhere else in the Company's service territory, the Company l-ooks at many factors, including: Consideration of visual impacts is not something special Idaho Power is Ketchum. It is somethlng Idaho Power routing a new line, along with many 10 11 72 13 74 15 o Land use (existing and future) 16 o Right-of-way availabili-ty (public or 1"7 private) and ability and costs to secure easements 18 o Devel-opment density 19 o Constructability-topography and terrain 20 o Access during construction and for future 21 mai-ntenance 22 . Appficabl-e codes and zoning requi-rements 23 o Public perception 24 . Impacts to businesses and homes PORTER, REB Idaho Power 18 Company 1 2 3 4 5 6 7 B 9 o Visual- o Noise o Radio o Safety towers on corners that impacts and aesthetics impacts interference impacts impacts (close to buil-dings, big block vision, etc. ) o Existing el-ectrical facil-ities o Existing l-inear facillties (roads, railroads, canals, trails, etc. ) o Natural- resource areas 10 Man-made obstructions (buildings, signs, 11 etc. ) 72 a Natural obstruction (vegetation, trees, 13 1akes, r j-vers, etc. ) L4 a Economics 15 a Schools 76 a Airports and heliports t7 Military facilities 18 a Shooting ranges (high vandalism) L9 o Cultural areas 20 o Threatened and endangered species and 2l habitat 22 When considering these factors, Idaho Power works with communitj-es and city/county l-eaders to find the best route that balances impacts with costs. 23 PORTER, REB Idaho Power L9 Company 24 1 2 3 4 5 6 7 8 9 O. why transmission line is building an overhead 138 kV through downtown Ketchum not a or viable solution and not appropriate to be used baseline ? Typically, the Company looks center and minimize impacts. practical as the for ways to build Unfortunately, vaIley and the already being line. Most engr-neer l-ine around a city the Ketchum-Sun Val-l-ey area is one option for bui1ding around used by the existing Wood River cities have reasonable routing A 10 options where a balance can 11 be found between impacts and costs. The North Val1ey does !2 not. l-n a narrow the city is to Ketchum to Ketchum, it is true that anWith respect could theoretically 13 t4 15 76 71 20 27 24 route an overhead transmisslon streets, and design it so that it would meet 18 street. The Company 19 sidewal-ks and squeeze requi-rements. Idaho Power coul-d put the conductors out over the couJ-d put poles in the middl-e of energized conductors between j-s not a practical solution in this through the applicable design long clearance arms that buildings. case. Vflhen But that looking at all- the factors the Company 22 considers when siting a new transmission l-ine, it is 23 unreal-istic to try to force an Ketchum. It woul-d be similar to to overhead route attempting line today through site and through PORTER, REB fdaho Power 20 Company 25 buil-d a new overhead transmission 1 2 3 4 5 6 1 8 9 downtown Boise. It j-s not reasonabl-e to expect this to occur because of the impacts, not just visual- or aesthetic, but impacts as a whol-e. O. As the Vice President of Transmission and Distribution Engineering and Construction, did you provide any direction to Mr. Ange11 with regard to pursuing the overhead transmlssion l-ine option through the downtown Ketchum corridor? A. Yes. Idaho Power investigated severa1 routes and sol-utions for continuj-ng the overhead portion of the 138 kV transmission l-ine al-1 the way to the Ketchum substation, including overhead transmj-ssion through downtown Ketchum. In addj-tion to all- of the challenges of providing an overhead transmission option that are fuI1y described in the Company's Application, Mr. Angell's direct testimony, and in dj-scovery responses, Idaho Power considered the ability and probabl-e costs of securing the necessary easements. Securing easements through the residential and downtown areas of Ketchum will- be problematic. The Company believes that it woul-d be required to condemn property, potentially need to buy out property, be subject to inverse condemnation claims, and spend years in court. Idaho Power anticipates these Iega1 actions will delay the transmission l-ine project for significant periods of time and perhaps indefinitely, and 10 11 t2 13 74 15 L6 L1 18 19 20 27 22 23 24 PORTER, REB 2L Idaho Power Company 25 1 it woul-d be extremely difficult to estimate what the total 2 cost could be. The ultimate result will- be Idaho Power's inability to for the North achieve the reliability improvements needed ValIey. The Company believes 3 4 5 6 7 8 9 viable to buil-d an overhead that it is impractical and not transmi-ssj-on line through too many impacts and the costare 10 downtown Ketchum. There and time (and associated easements afone make the references an estimated legaJ- challenges) to secure project infeasible. Staff cost of $18.5 mi]]ion for the conductors. of the estimate. 11 downtown Ketchum overhead route option, and it is important 72 to note that a specifi-c cost estimate was not developed for 13 the downtown Ketchum portion of this route as it was deemed 14 to not be viable. A theoretical route through Ketchum 15 woul-d require the majorlty of overhead structures to be a L6 variation of a larger steel corner or dead-end type of 77 structure required to make the numerous 90 degree turns, 12 and 18 foot18span buildi-ngs, and support the estimated Davit arms which hol-d the insulators and Generj-c costs were used for this portion 79 21, The actual cost could be much more and, more 22 importantly, to determine that cost wou1d requj-re 23 significant additional- engineering and design cost and 24 investigation, for something the Company determj-ned to not 25 be feasibl-e. Therefore, I instructed Mr. Angell and his 20 PORTER, REB Idaho Power 22 Company 1 2 3 4 5 6 7 I 9 team to determine alternative cost-effective sol-utions for providing a rel-iabl-e source of energy to the North Va1ley. For all the reasons dj-scussed, I did not consj-der a 138 kV overhead transmission line through Ketchum an appropriate or viabl-e basel-ine solution. Idaho Power bel-ieves that the most viable and practical demands for the residents approach for meeting the el-ectric of the North Valley is with the a 138 kV overheadCompany's proposal transmission line to construct from the Wood Ri-ver Transmission 11 10 east to Buttercup Road, then north along the bike Station, path and 72 Highway 15 to Elkhorn Road, at which point the transmission line woul-d be constructed underground and proceed along the hJ-ghway and in road rights-of-way to the Ketchum substation. Throughout the Company's testimony, this route has been identified as the Underground Transmission-TP1 option, and is the solution the Company views as striking a bal-ance between the Company's obligations to provide low- cost, reliable service and the communities' interests. This is the option for which the Company is seeking a CPCN. Idaho Power can provide the North Valley community the adequate reliabi1ity it needs and the Company stands ready to do its part. Idaho Power respectfully requests that the Commission issue an order: (1) specifically finding that the present and future public convenience and necessity requires the construction of a new l-38 kV 1_3 1-4 15 76 L1 1B 19 20 27 22 23 24 PORTER, REB Idaho Power 23 Company 25 1 2 3 4 5 6 7 8 9 transmission line and related facilities to provide redundant transmission service from the Wood River substatlon, near Hailey, into the Ketchum substation and (2) specifically granting the Company a Certificate of PubIic Convenience and Necessity for the construction of such l-ine and facilitles identified in the Company's Application as Underground Transmission-TP1. Such facil-ities are required for Idaho Power to meet its obligation to reliably provide service in the public interest, including the porti-on of that lj-ne that must traverse downtown Ketchum with an underground configuration. 0. Does this conclude your testimony? A. Yes, it does. 10 11 t2 13 t4 15 !6 77 1B 19 20 2L 22 23 24 PORTER, REB Idaho Power 24 Company 25 1 2 3 4 5 6 7 8 9 ATTESTAIION OE' TESTIMONY STATE OF IDAHO <!q County of Ada I, N. Vern Porter, having been duly sworn to testify truthfully, and based upon my personal knowledge, state the following: I am employed by Idaho Power Company as the Vice President of Transmission and Distributj-on Engineering and Constructi-on and Chief Safety Officer and am competent to be a witness in this proceeding. I decl-are under penalty of perjury of the laws of the state of Idaho that the foregoing pre-fil-ed testJ-mony j-s true and correct to the best of my information and belief. DATED this 23'd day of June 2077. N ern Porter SUBSCRIBED AND SWORN to before me this 23'd day of June 20L7. l.SB 10 11 1,2 13 l4 15 L6 1-7 1B L9 20 2L 22 23 24 25 26 27 28 29 30 31 SstARy rra,+Notary Publ c for Idaho Residing at:Boi-se Idaho My commission expires:02/04/2021: PORTER, REB 25 Idaho Power Company Ft-r 6 *,*Ip I .1 f.:ar t CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 23'd day of June 2017 I served a true and correct copy of the REBUTTAL TESTIMONY OF N. VERN PORTER upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Daphne Huang Camille Christen Deputy Attorneys General ldaho Public Utilities Commission 47 2 W est Washington (83702) P.O. Box 83720 Boise, ldaho 83720-007 4 Sierra Club Kelsey Jae Nunez KELSEY JAE NUNEZLLC 920 North Clover Drive Boise, ldaho 83703 Zach Waterman Director, ldaho Sierra Club 503 West Franklin Street Boise, ldaho 83702 Michael Heckler 3606 North Prospect Way Garden City, ldaho 83714 Kiki Leslie A. Tidwell Peter J. Richardson RICHARDSON ADAMS, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, ldaho 83707 Kiki Leslie A. Tidwell 300 Let'er Buck Road Hailey, Idaho 83333 X Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email daphne.huano@puc.idaho.oov cam i I le. ch risten@puc. idaho.qov _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email kelsev@kelsevjaenunez.com _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email zack.waterman@sierraclub.orq _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email michael.p.heckler@omai!.com _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email peter@richardsonadams.com _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email ktinsv@cox.net CERTIFICATE OF SERVICE - 1 Rock Rolling Properties, LLC, and Rock Rolling Properties #2, LLC Gregory M. Adams RICHARDSON ADAMS, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, ldaho 83707 Rock Rolling Properties, LLC Rock Rolling Properties, LLC c/o Kris Dondero P.O. Box 739 Sun Valley, ldaho 83353 Rock Rolling Properties #2, LLG Rock Rolling Properties #2, LLC c/o John Dondero P.O. Box 739 Sun Valley, ldaho 83353 City of Ketchum Matthew A. Johnson Wm. F. Gigray, !l! WHITE PETERSON GIGRAY & NICHOLS, P.A. 5700 East Franklin Road, Suite 200 Nampa, ldaho 83687 lndividual Laura Midgley 231 Valley Club Drive Hailey, ldaho 83333 CoxCom, LLC C. Tom Arkoosh ARKOOSH IAW OFFICES 802 West Bannock Street, Suite 900 P.O. Box 2900 Boise, ldaho 83701 CERTIFICATE OF SERVICE . 2 _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email oreq@richardsonadams.com _Hand DeliveredX U.S. Mail _Overnight Mail _FAX_Email _Hand DeliveredX U.S. Mail _Overnight Mail _FAX Emai! _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email mjohnson@whitepeterson.com _Hand DeliveredX U.S. Mail _Overnight Mai! _FAXX Email Midolev221S@qmail.com _Hand DeliveredX U.S. Mail _Overnight Mail FAXX Email tom.arkoosh arkoosh com Christa Bearry, Legal Assistant