20160831Comment.pdf

F<.ECE IVED
20 Io .c,UG 3 I PM 3: I 8
TO: Idaho Public Utilities Commission
FROM: Kiki Tidwell
I request that the Idaho PUC deny Idaho Power's request for a new 'redundant' transmission line in
Blaine County until a third party cost benefit analysis of alternatives has been completed.
Dear Idaho PUC:
Idaho Power will be applying to the Idaho PUC in September for a 'redundant' transmission line from the
Hailey substation north to Ketchum on Buttercup Rd along Hwy 75 where existing distribution line is,
crossing from east side to west side of Hwy at East Fork Rd. The height of Poles 56'6" high, 24" base
metal transmission poles with a distribution line on as well as transmission. The line is proposed to
underground at Elkhorn Rd to Ketchum substation at no additional cost to Ketchum residents, although
undergrounding costs 10 times as much as an overhead line. The cost to ratepayers will be $30 million.
The existing transmission line during the 30 years from 1980-2010 has only had 8 outages, 4 for less
than 5 minutes, the longest being 148 minutes. The existing line has spare capacity for anticipated
growth.
The proposed second transmission line does not provide backup power. During the Christmas 2009
outage two lines failed south of Hailey substation, no power was coming into Hailey. The proposed line
would have not brought any power north, would not have helped at all.
IPCo considers it redundant, even though The Valley Club, the Heatherlands, and Buttercup Road were
all evacuated during the last fire, so if two lines are located in that corridor, there is not true
redundancy. On the proposed route, the two lines cross at the Peregrine Ranch/Sagebrush Arena
corner. If true transmission line redundancy is to be achieved, at the bare minimum, the new line
should be buried in this corridor, rather than in Ketchum.
IPCo believes undergrounding the existing transmission line would be too expensive. However, they
have not explored undergrounding only the part of it that is difficult to access -over the Elkhorn hill to
Ohio Gulch-approximately 3.5 - 4 miles. Potentially, a $5-6 million cost to bury just this portion. The
rest of the line is accessible easily to repair.
ll?Co has not hired a qualified third party to fully explore improving the north county with a microgrid,
backup storage, and solar, diesel, and geothermal distributed generation, which would provide
emergency power. Potentially for 1/101h of the cost of the proposed transmission line, a backup diesel
generator could be installed now at Ketchum and SV substations within a matter of weeks or months
and provide backup emergency power. Microgrids and distributed generation with storage are working
all over the world today, including Navy installations.
I request that the Idaho PUC deny the proposed second transmission line request until a third party cost
benefit analysis for alternatives to the proposed line is developed.
Thank you,
Kiki Tidwell
300 Let'Er Buck Rd.
Hailey, ID 83333
208-578-7769
. Courtesy graphic
This rendering shows what the planned power line would look like adjacent to state Highway 75 at Ohio Gulch. north
of Hailey.
Idaho Power Co. pitches case
for 2nd Hailey-Ketchum line
Undergrounding work could cost $2.6M to $5.5M, depending on project
By PETER JENSEN
Express Staff Writer
A second Idaho Power
transmission Une running
between Ketchum and Hailey will
be an insurance policy in case the
existing line fails, but is it worth
the cost?
That's a snapshot of the
debate that occurred in a town
hall meeting at the Community
Library in Ketchum on Thursday
afternoon.
Aimee Christensen, executive
directoroftheSW1 Valley Institute
for Resilience, said Idaho Power
should provide independent
analysis on an alternative that
would include local renewable
energy production, a microgrid
and storage.
She said the costs of producing
has stated that it's company policy
to get those certificates for this
kind of transmission line project,
even if it's not legally required.
The PUC would open up a
public comment period before
deciding if it should hold hearings
on the request. It would make a
ruling after a period of several
month.
The need for a second
transmission line running up
the Wood River Valley has been
debated for several years, and
Thursday's meeting proved the
debate is far from settled, even
with the project moving toward
regulatory review.
Idaho Power provided a series
of cost estimates, depending on
how far south of Ketchum the line
would go underground.
Ketchum residents, and that it pay
the city ofSW1 Valley a franchise
fee of 3 percent, which would be
covered by Sun Valley ratepayers.
Unlike Ketchum, Sun Valley does
not currently assess a franchise
fee on Idaho Power.
If the line goes underground
at Owl Rock Road, Idaho Power
proposes a loca -improvement
district. A surcharge would need
PUC approval, while the LID
could be created with City Council
approval.
Valley resident Lara McLean
accused Idaho Power of being
ruck in old habits in how it was
delivering electricity to the Wood
River Valley.
"You are doing business as
usual," McLean said. "What I
want to know is why."
Idaho Power representatives
ri:isnonded that the costs of
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Assumptions:
Load • llMW peak power, lSOMWh energy demand
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Existing Generation • llMW DG, 15,000 gallons diese l per day
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t
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Storage none
Capital cost $3M
Running Cost $22M per year diesel
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I PV & Storage solution
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Jean Jewell
From:
Sent:
To:
Subject:
Attachments:
From: Kiki Tidwell
secretary
Wednesday, August 31, 2016 10:14 AM
Jean Jewell; Diane Holt
FW: Addition to my written submission
KMcCall Analysis of Power Line.doc
Sent: Wednesday, August 31, 2016 10:13:53 AM (UTC-07:00) Mountain Time (US & Canada)
To: secretary
Subject: Addition to my written submission
Dear Idaho PUC,
Please find attached more information about the Blaine County transmission line background to be attached to my
written submission, which you should have received by mail. Please note this analysis was completed in 2010 and
needs to be updated as to the current proposal, but gives you quite a bit of historical information.
Thank you,
Kiki
Kiki Tidwell
300 Let Er Buck Rd
Hailey, ID 83333
208-578-7769
1
Idaho Power Co. Proposed Subtransmission Line:
Introduction
Hailey -Ketchum
An Investigative Analysis (May 2010)
by
Kerrin McCall
The Wood River Electrical Plan (WREP ) completed in December 2007 by
Idaho Power Company (IPCo) addresses the current electrical supply system
for the Wood River Valley from Timmerman Hill to the SNRA and
recommends new infrastructure and routing for the entire system . Show
map from EST presentation. Exhibit 1 The following document only
addresses the North Valley component of the WREP which is a 138kV
transmission line proposed to be constructed along Highway 75 between the
Wood River Transmission Station just north of Hailey and the Ketchum
Substation. Show map when available Exhibit 2. The proposed line would
serve residents and businesses from north of East Fork to the Sawtooth
National Recreation Area. The purpose of this analysis is to provide
information concerning this project in addition to materials presented by
Idaho Power so that the public can make an educated decision about the
need for an additional transmission line.
Community Advisory Committee (CAC)
Idaho Power invited 19 members of the Wood River Valley (WRV) community
to help layout the WREP. The committee is represented by city and county
government officials, a developer, a rancher, the BLM and USFS, a former
Blaine County Commissioner and alternate representatives from the Sun
Valley Company. A list of the CAC members is included as Exhibit 1. The
team met with Idaho Power through the winter and spring of 2007 to learn
about electrical generation, transmission, energy efficiency and the
regulatory process. The committee then worked with IPCo to lay out the
transmission line routes and substation sites. On April 12, 2010 the CAC
reconvened to address the entire proposed system and refine the route of
the North Valley transmission line. Although some members of the original
CAC are no longer participating, including the one representative from the
environmental community, IPCo, when asked if new members could join,
declined, saying that there was too much background information and history
for a new person. It is critical that the environmental community is
represented on the CAC and currently there is no environmental
representative. The WRV, and the North Valley in particular, is a very
environmentally sensitive area and a majority of the community members
want infrastructure additions reviewed from environmental and aesthetic
perspectives and values. IPCo should not exclude the environmental
community from the CAC. Instead they should make every effort to orient a
new CAC member from the environmental community to review and
understand WRV CAC history from 2007 to the present.
History of the Line -1995
On June 2, 1995 Idaho Power Company filed an application with the Public
Utilities Commission (PUC) requesting an amendment to delete prior
authorization to construct a new 138kV transmission line from Hailey to
Ketchum. The purpose of the proposed line was to provide backup service
(redundancy) for the existing 138kV line which runs north and east out of
Hailey through Elkhorn to the Ketchum Substation. Show map form EST
presentation Exhibit 3. IPCo's filing for cancellation was based on "right-of­
way problems and the extraordinary measures it has taken to improve the
dependability of the line which has an excellent record of reliability. "
(Amendment to Certificate July 14, 1995 p. 1)
At the time of the application, Dan Olmstead, IPCo district manger in 1995,
said that "Laying a power line is typically controversial, but this one is more
so because it is not needed to address capacity problems. Olmstead
continued " It's up to the customers whether they want to live with one line
and put up with the minor inconveniences of interruption of service, or do
they prefer to build another line they would have to look at forever." Idaho
mountain Express, February 15, 1995.
IPCo performed an extensive study for the feasibility and need for an
additional 138kV line which reviewed capacity and reliability requirements for
service to the North Valley. The study concluded that the existing line with
a 120MW (megawatt) load capacity was capable of handling the maximum
buildout for the North Valley. It also stated that the line had "an excellent
record of reliability (only 3 unplanned outages in the past 14 years, 1981 -
1995, for a total duration of three minutes)", and that the "Company had
taken a number of steps to further improve the line's reliability". (Application
for Ammendment Case IPC-E-95-6 June 22, 1995 Page 1) These steps
included the following:
1. Structural Assessment-Energy Data Management of Colorado performed
a field inspection and structural analysis of the poles, cross-arms, insulators
and conductors which confirmed that the line was in good condition and in
compliance with the National Electrical Safety Code Standards.
2. Electrical Assessment: -Energy Data Management and Power Engineers
of Hailey analyzed the historical performance of the line from 1980-1994.
The line was determined to have an excellent outage history with only two
unplanned outages between 1981 and 1995 for a total duration of 3 minutes.
3. Fire Protection: Osmose, Inc coated the transmission poles with Fire­
Guard protectant which is designed to protect the poles through 3 fires.
4, Avalanche Study: Power Engineers and Energy Data Management
determined that all structures had adequate strength to withstand a 50 year
recurrence avalanche.
5. Enhanced Maintenance Plan: Idaho Power has developed an enhanced
maintenance plan to repair and replace power line components as needed.
6. Emergency Action Plan: Idaho Power has prepared a detailed,
comprehensive emergency action plan to facilitate a rapid and effective
response to a service outage or other emergency regarding the power line.
(Application for Amendment to Certificate June 2, 1995 pp 4-6)
In summary for the 138kV line application, Idaho Power completed an
extensive public participation process regarding the possible construction of a
second or redundant transmission line from Hailey to Ketchum. IPCo reported
to the Idaho Public Utilities Commission that the "overwhelming response
from the parties commenting was that, despite the unavoidable risk of an
outage to the existing transmission line, the proposed transmission line
should not be built." The reasons for public opposition to the line included
"difficulty in finding an acceptable route, aesthetic impacts, health and safety
concerns, and the excessive cost of burying part or all of the line," (which
would be incumbent on the community to pay for). (Above 2 quotes from
Application for Amendment to Certificate June 2, 1995, p.6) The cost in
1995 of an overhead line could have been $3 -$4 million dollars and as
much as $14 million to bury. !PUC concluded in their comments to the
Application for Amendment July 14, 1995 p. 1, that "If longer and more
frequent outages occur in the future or if the Company experiences
substantial growth in the Ketchum / Sun Valley area, it would once again be
appropriate to examine the options. (To date neither of these issues has
occured.) Sun Valley Company, Idaho Power's biggest customer in Blaine
County favored maintenance of the existing line over building a redundant
line. ( ties News, Twin Falls, February 15, 1995) In August 1995, the !PUC"
removed the authority for the construction of a second 138kV line
Current Transmission Line Proposal
Visual Impact { current pole height plan not presented here }
To date there are two height scenarios with more information from IPCo in
July. 1. The steel or wood poles of this transmission line could be 60" tall
much taller than the distribution poles currently running along the highway
or nearly three times the height of a two story home. They would be spaced
every 300' meaning there could be 175 -200 poles. There will be several
tiers of line including the existing distribution line strung on these poles and
a lightning shield on top. Show photos Exhibit # 2. The poles could be 55'
high with a lightning shield and the entire distribution line buried.
Considering that Blaine County recently rejected 40' residential wind turbines
in the highway view corridor because residents were opposed for reason of
aesthetics, the height of these pole could be an issue.
The transmission line can be buried for the total length or part of the length
of the line which would eliminate the visual impact. Burying a 138kV line
costs ten times more than an overhead line and the costs are incumbent on
the community to pay. When looking at a variety of scenarios in the next
section of this document, it becomes clear that burying all or any of the line
is expensive.
It should be noted that the existing line, built in 1962, was built out of sight,
off the highway corridor, and over three miles of difficult terrain instead of
straight from Hailey to Ketchum. IPCo has not been able to give information
about the decision many years ago to build the line along this route. Surely
there are documents regarding the acquisition of the Right of Way for the
1962 line that would help understand this decision. One can surmise that the
community and IPCO did not feel it was appropriate to build it along the
highway in the view corridor.
In addition to the transmission line a "control house" would be built at the
Ketchum substation. Normally a control house contains relays, batteries and
switches to operate equipment when power fails -in essence these are
security devices and are normal in a substation. Details of this structure have
not yet been disclosed.
Proposed Route ( final route not presented here)
Currently, IPCo has not yet provided a final routing graphic. When the
graphic is available it will be provided on the Environmental Resource
Center's website. The following is the best information on the route as of
July 1, 2010. The 138kV line will leave the Wood River Transmission Station
north of Hailey crossing to the west side of Hwy 75 and run to Greenhorn
Gulch and Golden Eagle where it will again cross the highway and proceed
north on the east side of the highway to Elkhorn Rd. Here, the line will split.
Presumably creating two 138kV lines. One section will run on the North side
of Elkhorn Rd. to the Elkhorn Substation across from Twin Creeks (where
the existing 138kV runs to the substation). The other 138kV line will go
through Ketchum to the Ketchum Substation on Sun Valley Rd. Some or all
of these sections could be buried at a cost to the taxpayers. The section
going through Ketchum to the substation would be buried as the City of
Ketchum's height restrictions would not allow poles of the proposed height.
Each block the line passes through would be disrupted for two weeks.
Additionally, Ketchum will not allow any new overhead infrastructure within
the city limits and the existing poles are already maxed out. (verbal
communication to me from Randy Hall, December 2011). All above ground
sections would require conditional use permits from the county (Scenic
Corridor code) or the cites involved. It should be noted that the route of
the proposed line follows the "Sawtooth Scenic Byway" the 100th National
Forest Scenic Byway. Beginning in Shoshone, the route runs north through
the Wood River Valley and into the Sawtooth National Recreation Area.
Cost
The cost of this line in 2013 dollars depending on route, overhead and
underground segments, and distribution line treatment, will be
approximately $23 million. The cost of new overhead infrastructure would be
paid for by ratepayers statewide. In 2007, when the WREP was competed,
the cost per mile overhead was $300,000 and the buried cost was
$3,000,000. Any part of the line that is buried is ten times the cost of an
overhead line less the cost of the overhead per mile. For example in 2010
dollars: one mile of overhead line costs $400,000 and one mile of buried line
is $4,000,000 less $400,000 or $3,600,000 per mile. The cost of the buried
line is incumbent on the community. A LID, suggested by IPCo, would to pay
for the buried line at a cost of $250 per $100,000 property value
Permits, Process, Timelines ( current timelines not included }
A conditional use permit will need to be issued from Blaine County, the cities
of Ketchum, and Sun Valley if IPCo crosses their jurisdiction with the new
line. A building permit is required for the "control building" needed at the
Ketchum Substation. Prior to these applications IPCo will conduct public
involvement for several months throughout the valley. If this involvement is
only in the form of open house presentations, there is very little opportunity
for open group discussion and dialogue which gives the public the chance to
hear, participate in and document these discussions. As of August 15, 2010,
there is no specific timeline for this public education as engineering and cost
analysis need to be completed before conversations with the city and county
officials, stakeholders and the rest of the public. Public hearings will be
scheduled for sometime in the fall. Formal public hearings with the Idaho
Public Utilities Commission (!PUC) and IPCo officials present a great
opportunity to present testimony that is meaningful and will require a formal
response from IPCo.
The Christmas Power Outage and How It Relates to the
Proposed Line
The 2009 Christmas power outage, as untimely as it could possibly have
been, did not result from any failure of the Hailey to Ketchum transmission
line but the outage does relate to the current Hailey to Ketchum proposal in
that it clarifies where infrastructure improvements are needed. The
unfortunate outage was a result of the failure of the Midpoint and then the
King line, to which the load was transferred after the Midpoint Line failed.
These lines run from south of Shoshone and Hagerman respectively and they
feed the existing Hailey to Ketchum line. If redundancy is an argument for
reliable power, would a third line south of Hailey have made a difference?
Certainly, a second line from Hailey to Ketchum would have had no effect on
supplying electricity to the valley's guests, residents and businesses during
the 2009 Christmas power outage. The public needs to be made fully aware
that the causes of the Christmas outage had absolutely nothing to do with
the existing Hailey to Ketchum line.
The Midpoint and King Transmission lines
Problems exist on the Midpoint and King lines and these lines should be the
first priority in transmission upgrades. Idaho Power has failed to give full
attention to the plan they indicated in Appendix B p. 7 of the WREP which
states that. "If the stronger line is out of service (Midpoint to Wood River
Transmission Station ) , the remaining line service capacity may limit the
ability to service the load. If this were to occur when loads in the Valley
were high ( a cold winter day), it would likely result in some Valley electrical
load being interrupted via rotational outages". This is what happened at
Christmas but with an extended outage (there were no rotational outages
which is an IPCo activated event, and were not executed by IPCo and
arguably might have prevented the Christmas 2009 outage). Since 2006 the
Midpoint line has not had enough capacity to serve the entire electrical load
should the weaker line be out of service. On P. 7 of Appendix B in the WREP,
the report states that the "Midpoint Line must be able to serve the entire
load 90% of the year." 90% of the load is 92MW. This goth percentile load
grew 4MW in one year prior to 2007. The line failed because of heavy icing
(which could have been avoided with state of the art monitoring) and when
the load was transferred to the King line that line failed because of faulty
splicing ( a maintenance issue which should have been attended to before
problems occurred) and the subsequent failure of 6 aluminum conductors
held within the splicing. A question to ask is "What has IPCo done to the
Midpoint and King Lines since the 2007 WREP to manage this issue?
Contrary to some reports, the Christmas outage was not a perfect storm
because the problem was identified years ago and was not attended to.
Even now, after the Christmas outage, IPCo still prioritizes building a
redundant line from Hailey to Ketchum, where minimal outages have
occurred, an intensive maintenance schedule exists and reliability is
excellent, before addressing a poorly maintained and faulty system to the
south.
The WREP Implementation Plan p. 16 states "The recommendations of the
CAC cover infrastructure improvements to the Idaho Power system that will
deliver sufficient power at the Wood River Valley's buildout. Not all facilities
are needed in the near term and will be phased in as the Valley's load
increases. " The first improvement in the five year plan is to " Build second
138,000-volt transmission line between the Wood River Transmission Station
in Hailey and the Ketchum Substation. This is the top priority project." After
that, in the 5 year plan comes the configuration of new 138kV lines to
improve the Midpoint system south of Hailey, including a new substation
south of Timmerman Hill. The questions raised here are: 1. If IPCo is
attempting to provide sufficient (adequate, enough) power, then why are
they prioritizing a redundant H - K line when the existing line is reliable with
sufficient capacity for North Valley buildout yet dependent upon an
inadequate southern system? 2. What are the criteria for sufficient power?
Before the Christmas outage IPCo knew the Midpoint line was inadequate so
why did they not have the most effective technology to quickly locate the
point of failure? Cameras and remote monitoring should be standard. Icing
on the line is certainly not a new phenomenon. The longest span with the
least ground clearance is the first to go, yet a spokesperson for IPC said
"Repair crews didn't know what and where the problems were." During
Idaho Power's January meeting before the Blaine County Commissioners
concerning the Christmas outage they said that company plans to more
carefully check lines for breakdown. A more efficient and thorough
maintenance schedule could certainly prevent problems evidenced by the
enhanced maintenance of the existing Hailey to Ketchum line which has had
minimal outages. State of the art technology should be a mandate by the
IPUC. Instead, antiquated and slow methods of surveillance seem to be the
accepted standard that ultimately lead to spending millions of ratepayer
dollars to build redundant transmission lines as backups rather than
maintaining to the highest standard existing lines as in the attention given to
the Hailey to Ketchum 138kV.
If Idaho Power and the community are concerned about reliable power then
the first issues of concern and infrastructure improvement should logically be
the Midpoint and King Lines. Recent charts from IPCo ( Bryan Hobson's
WREP presentation to Ketchum's Energy Solutions Team shows the two south
lines combined sustained outages from 1996-2006 as 44 sustained outages
and 56 momentary outages and 4 of each for the Hailey to Ketchum line.
However, Table 5 Appendix B p. 8 of the WREP shows that from 1996-2006
there were 37 sustained outages and 72 momentary outages for the two
south lines and 4 of each for the Hailey to Ketchum Line. There is certainly
some discrepancy with IPCo's outage figures, but what is significant is here is
that the figures justify giving infrastructure priority to the Midpoint and the
King lines over the Hailey-Ketchum Line. (See Exhibit 6). From this data it
would seem reasonable for Idaho Power to first address the urgency of the
south lines and fixing the problem where there are statistically more outages.
Instead it is prioritizing the North Valley line which has had minimal
problems. The two south lines need to be infallible if reliability is the primary
concern for our community and IPCo. It must be reiterated that two faulty
lines feeding the reliable existing North Valley line and a proposed new North
Valley line will not give this community reliable power.
IPCo Mandates and Criteria for Reliable Power
Need -Redundancy
Redundancy and capacity are the two components that determine the need
for reliability offered by an additional transmission line. A redundant line
serves to maximize dependability by being available to carry its total load
plus the total load of the line it is backing up the load when the line it is
backing up has an outage caused by weather, operator error (i.e. IPCo's
mistake), range fires, maintenance or equipment failure. Redundancy as
defined in the WREP is "Two separate lines that can handle extreme peak
loads alone without rotational outages." (This statement seems to verify that
if "rotational outages" had been used by IPCo during the Christmas 2009
problems or any other scenario where there is not a redundant line, the need
for a redundant line would not be necessary. Put another way, rotational
outages when properly used are an alternative to a redundant line. As used
in engineering, redundancy means "the inclusion of extra components that
are not strictly necessary to functioning, in case of failure of other
components." Simply put, a redundant line is a backup line. Its connotation
is "unnecessary".
The issue of redundancy is the same now as it was in 1995 when IPCo
Regional Manager Dan Olmstead said "It's up to the customers whether
they want to live with one line and put up with the minor inconveniences of
interruption of service, or do they prefer to build another line they would
have to look at forever." (Idaho Mountain Express, January 1995) It is
suggested that all the same studies, enhanced maintenance and emergency
action plans continue to be carried out on the existing line today as were
enacted in 1995 to ascertain and assure the line's reliability.
The existing 138kV line continues to have an excellent record of reliability
with only 8 outages over the last 15 years (a total of ten in 29.5 years).
Idaho Power maintains and services this line to a much higher standard than
most other transmission lines. There have been no outages on the existing
Hailey to Ketchum 138kV line in the last 3.5 years (2007-10). Bryan
Hobson, Transmission and Delivery Planning with Idaho Power, supplied the
following information for the years 1995-2006: 2 momentary outages were
attributed to weather conditions (snow/ice loading) and 2 were caused by I
lightning . The momentary outages are defined as less than 5 minutes. Most
of them were a few seconds. Of the 4 sustained outages, the cause of one
was unknown, and then there was one each due to vandalism, equipment
failure, and maintenance. The 4 sustained outages were 5 minutes, 104
minutes, 148 minutes (resulting from vandalism) and 58 minutes. There
have been no outages in the last 3.5 years (no data from 2010 to
present) This can be considered proof that the line's excellent maintenance
program has paid off.
Bryan Hobson, Transmission and Delivery Planning IPCo, says that "The
total length of the existing Wood River Substation to Ketchum line is 12.4
miles. I think the term 'difficult terrain' is subjective, but I would say that
most of the line (at least 75% is in difficult terrain because it does not have
easy access ( especially in the winter) or it is located near the base of a
mountain or on the slope of a mountain where avalanche and or fire hazards
exist." An independent tracking of the line by vehicle and USGS topographical
maps of the Hailey and Sun Valley quadrants (which show the line's route)
reveal that there are approximately 7.5 miles which run adjacent to a county
or city road which allows for full access for repairs year round. There are 1.5
miles of the route on the north side of East Fork Road which although visible
from and parallel to the road runs along the steep uphill side of the road.
Finally, there are 3.5 to 4 miles which are have difficult access summer and
winter. These figures with nearly 75% of the line with reasonable repair
access indicate the reverse of Hobson's assessment.
From these figures and the data on maintenance and outages, it can be said
that the line continues to have an excellent record of reliability. Considering
the existing line's record and its access for repairs, the delivery of future
electrical supply can be considered as reliable as it has been in the past.
That is if the south lines that feed the Hailey to Ketchum line are well
maintained and given priority upgrading. It will serve the community well to
review the reasons why a proposed line was turned down in 1995
Regardless of the line's record of reliability, there is a perceived need for a
redundant line within segments of the community, specifically the business
sector, the City of Sun Valley and (SVCo ). There is the fear that another 24
hour outage is possible, even though the Christmas outage did not occur
as a result of the failure of the Hailey to Ketchum line, but as the
result of the failure of the two south lines feeding the H-K line.
However, in conjunction with the Castle Rock Fire and the sustained, severity
of the economic downturn, the Christmas outage was another blow to
retailers. The perception that redundancy is a secure solution to future
outages is real to many, yet, as proven by the two failed south lines which
caused the 2009 Christmas outage, the most secure solution to prolonged
outages is excellent maintenance and state of the art surveillance on the
existing 138kV line serving Ketchum. From the perspective of the business
community, although the risk of transmission failure is very small, the
potential risk to the economy is large. SVCo has the largest stake in an
electrical outages and the Christmas outage was proof of their concern.
Although the company received a stack of letters expressing gratitude for the
manner in which the SVCo took care of their guests during the outage, there
is a deserved fear that another outage could happen with far worse results,
including not only the company's reputation but extensive and expensive
damage to pipes and infrastructure.
In researching this report, the question has arisen several times as to who is
driving the new line and should they not be the ones to pay for the buried
sections if the line is permitted. In conversation with a SVCo representative,
there was no explicit effort in this respect, but the company does support a
redundant transmission line and is represented on the CAC. IPCo is certainly
a driving force in pushing through a new transmission line. IPCo is
guaranteed a profit on capital investment. The more that IPCo invests in
infrastructure the higher their gross and net profit, thus higher dividends to
stockholders and higher compensation to executives. As discussed in the
section of this analysis titled " Distributed Power/ Microgrid /
Micropower, consumer controlled energy production, by means of solar PVs,
residential wind turbines and fuel cells, poses a threat to the business model
utilities have depended on for more than a century.
When reviewing the need for an additional transmission line, it must be taken
into consideration that reliability of electrical power delivery in the twenty
first century is subject to threats that are different and potentially more
severe than local outages. The Wood River Valley is part of an extensive
electrical grid. A major disruption on the Oregon coast could throw out
power in our community and has. If there were a desire to dismantle the
valley's electrical transmission, there would be nothing to stop a person with
that intention from tampering with more than one line. Our valley's electrical
system is connected to the south valley and the south valley is connected to
the regional grid. It is therefore pro-active and wise to consider how our
community can become more energy self-reliant and resilient to all manner
of electrical disruption. This subject is addressed in the section of this study
titled "Energy Self-Reliance and Renewable Alternatives".
Need -Capacity
Capacity is the maximum amount of power in megawatts MW, carried by a
transmission line. Uninformed residents in the North Valley believe that a
redundant line is needed to assure enough electrical power for the future
even though IPCo stresses that there is plenty of electrical capacity for North
Valley buildout. The existing Hailey to Ketchum 138kV line has a 120-
130MW capacity in winter when the demand is the highest (Application for
Amendment to Certificate, p.4 June 2, 1995). Powerlines are capable of
carrying more electricity in colder conditions. The historic winter peak line
loading was New Year's Eve 2007 with 64MW or 53.5% of capacity. Data
provided by Idaho Power show that in the following two years peak line
loading dropped : Christmas Eve 2008 at 61MW and New Year's Eve 2009
at 60MW. The Wood River Valley, especially the North Valley, has its peak
load in winter unlike the most of the rest of the state which has a summer
peak load due to air conditioning and agriculture.
In 1995 IPCo stated in its Application for an Amendment to Certificate that
IPCo's "current projections of electric demand in the Ketchum -Sun Valley
area indicate that the existing 138kV transmission line has sufficient capacity
to meet the area's electric needs for the foreseeable future". IPCo projected
that the winter peak load in 2005-2006 at 73MW. That is 9MW more than
the 2007 peak of 64MW, and only 8.5MW higher than 1994-1995. The point
being that electric use is actually far less than projected. This and other
extensive calculations, available upon request, substantiate IPCo's 1995
report and IPCo Manager Delivery Systems, Dave Angell, who stresses that
the proposed line is "not a capacity issue. It is continuity and business
driven." The proposed line is not needed to provide additional capacity is
and IPCo should make that very clear to the media and in all its public
presentations. Unfortunately, IPCo presentations are currently misleading in
that they do not distinguish between the North Valley, and the rest of the
Wood River Valley, the South Valley, which will require more capacity and
where IPCo has made their calculations. An example of this is from a
presentation made to Ketchum Community Development Energy Solutions
team:
Future: Capacity and Reliability (Explanation available upon request)
-Existing system can serve 15-20 years of growth
-Load growth will make existing reliability problems worse
-Additional transmission and substation capability likely required.
Capacity Details
To understand the distinction of capacity needs between the north and south
county we can take IPCo's figures for the south valley growth and
extrapolate them to the north valley. By means of comparison the historic
peak load consumed by Blaine County from Timmerman Hill to the SNRA was
99.SMW in the winter of 2006. (WREP Appendix B -Page 1). This demand
included an estimated population of 21,600, plus an unknown figure,
perhaps 5,000 for people staying in private residences and second homes,.
1,564 holiday guests in hotels and condominiums ( figures based on pillow
count and percentage of lodging occupancy taken from SV-Ketchum
Chamber of Commerce tourism profile) totaling 28,164 consumers, as well as
the business centers of Bellevue, Hailey, Ketchum and Sun Valley, and Sun
Valley Company (lodges and lifts).
For the purposes of analyzing capacity for the Hailey to Ketchum line, it is
essential to distinguish the North Valley (north of East Fork to the SNRA), as
that is the area the proposed line is to serve. The WREP does not make this
distinction in its calculations. The distinction is crucial and the following
calculations show definitively why capacity is not an issue for a second
transmission line.
Current ly, the estimated population of Ketchum is 3,500; Sun Valley 1,200
and the county population from north of East Fork to the SNRA, which is the
population the line will serve, is estimated at 5,000. This total population is
9,700 with available fig ures to date. Assuming an additional 6,564 electrical
users are added at the Christmas/ New Year's peak historical electrical load
(the same figure added in the calculations for the entire county in 2006)) the
total holiday population would be 16,264. That is 11,900 less than the
28,164 population estimated by Idaho Power to demand the historic peak
load of 99.SMW for the entire county, and 64MW or 53.5% of capacity for the
existing Hailey to Ketchum line as indicated again by Idaho Power in
Appendix B -Page 1 of the WREP. This means that the North Valley ( north
of East Fork) will need to grow by 11,900 people just to reach a load of
99.SMW and then by another 6,200 people on the existing line to reach
capacity of 120MW. That is an additional 18,100 people in the North Valley
(north of East Fork) bringing the total population to 27,800. Of course the
numbers are variable and some people use more electricity than others with
larger homes in the North Valley and greater wealth demanding more use.
Nonetheless the numbers needed to reach capacity are impressive. IPCo
certainly needs to publicly clarify this issue so that residents understand that
that there is no need for additional capacity.
Considering the current density and the limited land for construction due to
BLM and Forest Service public lands as well as the Hillside Building
Ordinance, the high cost of land, and an economy that can no longer be
sustained by construction as it has been for many years, it seems unlikely
that the pressure of population could ever demand 120MW in the North
Valley, unless the current population more than doubles its electrical
demand, which is highly unlikely. The trend is just the opposite as energy
efficiency, demandside management and energy conservation become more
important due to diminishing fossil fuels and increased renewable energy
capacity. The current problems with the BP Gulf oil blow out and the shut
down of coal-fired plants should help drive home the need for re-emphasis
on all sustainable activities and reduced dependency on fossil fuels.
Although the electrical supply must assure capacity for the highest use -
Christmas and New Year's Eve -these are only two days during a two week
holiday period when the demand is so high. The average winter peak load
for winters 2007 -2010 is as follows:
07 -08 47 MW 39.2% capacity
08 -09 46MW 38.4% capacity
09 -10 45MW 37.5% capacity
The WREP has projected the WRV growth by two means : Spatial Growth
Approach and Population Growth Approach. Although their calculations make
sense, they fail to distinguish the North Valley from the rest of the Wood
River Valley which has much more land available for population growth at
lower prices. This analysis "Wood River Valley Growth" is attached as
Exhibit 2. (not included here) For a full perspective on this issue of
capacity IPCo should be required to detail the load for the North Valley so
this material is documented as evidence that they are proposing to build a
line that exceeds the current and projected load for the area. This material
should be accessible to the public and regulatory bodies.
It is unusual to build a redundant line when the existing line is only 50 -60%
loaded. There are certainly factors that will increase peak demand. They do
not include the new River Run Gondola, the Sun Valley Golf Club Lodge and
The Dollar Mountain Lodge with its new high speed lifts and snowmaking as
they are already included in the figures for the peak load for 2009. What can
be considered new and substantial pressures on demand are proposed
hotels, Warm Springs Ranch, Sun Valley Company's development at the base
of River Run, affordable housing units, new buildings and the increasing use
in electronics -computers, flat screen televisions, cell phones, electronic or
computer driven cash registers, as well some population growth.
If the line is business driven, then IPCo should provide specific information
about what businesses are pushing for this line, or if it is IPCo influencing
businesses that the redundant line is necessary. This is not a normal "system
expansion" addition to the IPCo system because it is unusual to build a
redundant line when the existing line is only 50 -60% loaded. It should
therefore undergo significantly more scrutiny from IPCo customers,
regulators and public officials.
Need in Relation to Electrical Generation, Energy Efficiency,
Smart Grid
According to the company's Integrated Resource Plan (IRP), IPCo does not
currently have enough electrical generation capacity, is importing out of state
electricity and peak hour planning graphs indicate the very real possibility of
rolling blackouts in the coming years. Section 8. Planning and Portfolio
Selection, Peak Hour Planning, Figure 8.4 illustrates considerable peak hour
deficits reaching in excess of SOOMW by 2012 and continuing to grow
through the remainder of the 20 year planning period. It would, therefore,
make sense for IPCo to be investing more heavily in power generation than
building new transmission lines that will not have adequate electrons to
carry.
Throughout the WREP Idaho Power suggests that there are alternatives that
could displace the need for new utility infrastructure by lowering peak
demand which exists briefly during the important to the economy Christmas
holidays. Average peak demand, however, is significantly lower than the
winter peak. (In reiteration of previous statements in this report, the
proposed Hailey to Ketchum powerline is not needed for additional capacity.
However, for the purpose of education about responsible awareness of
energy use as a community goal, and in relation to climate change and
increased energy security, the following material is applicable.) One way to
effect peak demand is with Demand-side Management (OMS) or actions that
influence the quantity or patterns of energy use consumed by end users,
such as actions targeting reduction of peak demand. Peak demand
management does not necessarily reduce total energy consumption but could
be expected to reduce the need for investments in new infrastructure. Idaho
Power estimates that OMS along with improved building standards, energy
efficiency technology advancements and customer involvement will reduce
new electrical load. Various programs underway are listed in Appendix C -PP.
3 & 4 of the WREP. These programs enacted en force would address the
concerns of the Wood River Valley North as well as IPCO shareholders who
voted in 2009 to reduce greenhouse gases and increase renewable energy
production. Not mentioned in the WREP are advanced metering, energy
conservation, local renewable energy generating facilities, the
recommendations of the Northwest Power and Conservation Council which
envisions meeting 85% of new electrical demand over the next twenty years
to be met by energy efficiency.
Of all the efforts to reduce peak demand, the Smart Grid is the one
technology that also has the capability to dismiss the need for a redundant
line. If reliability is what our community and IPCo are looking for IPCo's
Smart Grid Investment Grant will initiate the application of this technology.
One smart grid benefit is called "self healing" because it provides
visualization and control systems that allow operators to detect disturbances
and take action before problems cascade into widespread outages like the
2009 Christmas outage. Smart grid technology applied to the existing line
could eliminate arguments for an additional transmission line
Energy Self Reliance and Renewable Alternatives
As this paper is being written half a million gallons of oil are spilling
uncontrollably every day into the Gulf Of Mexico causing catastrophic
environmental devastation. This tragedy is hopefully going to strengthen
the commitment of the Obama Administration to the immediate need for
developing safe and renewable forms of energy production. As more
emphasis is directed on a national level to the need for solar, wind,
geothermal and biomass for electrical generation as well as alternative and
non climate disruptive renewably powered automobiles, the state of Idaho,
with its very abundant renewable resources, has the opportunity and
responsibility to be a leader in renewable energy generation. Point in case:
Midpoint Energy, a Jerome based company is applying for a permit to build a
solar farm with 150,000 photovoltaic panels capable of producing 75 MW of
electricity enough power 45,000 homes, according to IPCo officials. This
unprecedented proposal in Idaho will compliment preexisting wind, biomass
and geothermal generation in the southern part of the state. Although Idaho
Power says in its Integrated Resource Plan (IRP) that the company is
aggressively pursuing renewable energy, its current portfolio does not reflect
that position.
Distributed Power / The Microgrid / Micropower
Distributed energy resources -what is being called the "microgrid" -are
consumer-driven, small-scale power generation technologies (typically in the
range of 3 to 10,000 kW ) located close to where electricity is used (e.g., a
home or business ) to provide an alternative to or an enhancement of the
traditional electric power system. Generating power on site, rather than
centrally, eliminates the cost, complexity, interdependencies, and
inefficiencies associated with centralized transmission and distribution. As of
four years ago, micropower was a third of the world's new electricity and one
sixth of the world's total. Companies like GE and IBM are talking about up to
half of American homes generating their own electricity, renewably, within a
decade and the evidence is growing that geographically distributed
renewables could deliver a 100% green energy future faster and cheaper
than big power projects alone. In his book, Small is Profitable'~ Amory
Lovins writes "Distributed generation means a redundant, resilient, secure
infrastructure -that's why military bases and hospitals have their own power
plants. Micropower can be more reliable because 98% of blackouts originate
in the grid." In the case of the Christmas outage, that is exactly what
happened. If Sun Valley Company, homes and businesses had had solar PV
installation on roof tops, the degree of electrical outage resulting from the
failure of transmission lines outside the North Valley would have been
substantially mitigated. That is not to say that distributed power is a
solution for energy reliability for an entire community, because energy self­
reliance is a matter of both choice and sufficient finances to purchase the
energy systems. It is most certainly one of the solutions. However, the
Smart Grid, mentioned earlier in this report, is a technology IPCo is
implementing which can be a real and very imminent solution for reliability.
Currently, in accordance with Idaho Power's net metering program, small
scale electrical generation systems without battery storage systems, send
excess power back into the grid. In the North Valley, that means excess
electricity would go into the North Valley electrical system to serve other
customers who would pay for it. Although IPCo credits the on -site producer
for excess power, the utility should be buying that power at the going rate it
pays larger producers and sending a check to the individual whose system is
generating power. As battery storage technology increases and the cost of
solar photovoltaic panels declines concurrently with the increase in state and
federal incentives along with business and residential tax credits, the future
of small scale electrical generation is realistic. Fuel cells (although dependent
on a small external fuel source like natural gas) are another source of clean,
on site power generation that can meter excess electricity back into the grid.
A major hindrance to micropower exists within the power structure of the
utilities and the edict for corporations to maximize profits for the
shareholders. Net metering puts utilities at a higher risk of losing revenue
because the consumer basically has free access to the power source. The
new energy world, where electrons are sourced locally, could be one of the
answers to our energy crisis and why the big utilities are fighting hard to
keep business as usual.
Alternative Energy Generating Technology
Solar Farms
Community based energy is electricity sourced from wind and solar generation
where local ownership of turbines and photovoltaic systems by small groups of
farmers, local governments and private individuals provides a sustainable and
secure means of producing renewable electrons while addressing climate
change and energy security. Regional energy production empowers
communities because they have a significant stake in how that energy is
owned and operated. Money spent on local energy stays in the community
creating a ripple effect in the economy.
IPCo states in the WREP that "The number of sunny days that the Wood
River Valley sees every year would seem to indicate that it would be an ideal
location for photovoltaic use." The report goes on to say that on a large
scale, however, solar energy sites would suffer from electrical transmission
required to deliver energy to the end users and limited space for an solar
farm. It safe to say that sub-transmission lines (138kV) would not be
necessary to carry the load especially for a solar farm with an output of 20 -
50 MW which could be served from IPCo's 12.5 and/or 34.5MW distributions
systems. A solar farm could offer locally generated electrical availability and
it could also provide a back up system for temporary outages. Distribution
lines which have smaller capacity could disperse the load on a rotational
basis during a North Valley outage.
A recent poll (March 2010) indicates that 75% of Americans approve of solar
installations on public lands that are not set aside for parks and nature
preserves. The Solar Energy Industries Association commissioned the poll
from the Gotham Research Group. What these results indicate is that
Americans see the necessity for developing domestic clean energy resources,
and believe that solar farms on large tracts of uninhabited, sunny land make
good business sense. With an abundance of public lands in the Wood River
Valley it makes sense to use some of this land to provide electricity with one
or more solar farms. Projects which are developed in the North Valley could
use existing and future distribution lines to send their excess power directly
into the North Valley system and could serve much of its electrical demand
as backup electrical generating facilities. Sun Valley Co. could build a solar
system out Trail Creek on Forest Service land. The City of Ketchum could
provide land near its water storage tank just north of town. Rooftop solar
farms could be constructed. Ohio Gulch with all the surrounding BLM land
and proximity to the existing transmission line is another possibility. If 405
acres in Jerome are projected to produce 75MW of electricity and the North
Wood River Valley is currently using 64MW or 53.5% of capacity at Christmas
peak demand, it would seem logical that the North Valley could produce
sufficient electricity with solar farms and distributed energy to act as a
backup source of power. People might respond to the idea of solar generation
in a snowy climate as "pie in the sky" and these arguments need to be
addressed with specific studies and research which must be addressed now.
IF Idaho Power builds a new line up the valley floor, it could preclude efforts
for a sustainable and resilient form of energy production. Ultimately, the
proposed 138kV would assure that this community continues to get its
electrical energy from non renewable sources (coal and natural gas) as well
as hydroelectric.
Wind
In 2006 a study by Gerald Fleishman of the Idaho Energy Division entitled
"Blaine County Wind Farm Possibilities" stated that four mountain ridges
within a short distance of Hailey could justify Blaine County's investment in
the investigation of wind power development. The study shows that wind
power on the ridges east and west of Hailey ranges from class 3 - 5 and that
45 turbines could provide llOMW electricity. The system could also generate
income to the county from $36,854,625 to $73,709,250 over the next 20
years. The county's finance options for such a project include the Minnesota
Flip model or clean renewable energy bonds.
This project would not be located in the North Valley so it could not serve as
a redundant or backup system because it would rely on the existing 138kV to
carry the load and it does present problems in relation to the Scenic Corridor
Ordinance which has already blocked residential turbines. It is, nonetheless,
an appealing possibility for renewable energy for the South Valley.
Commitment for a Sustainable Energy Future
More than 50% of our electricity in the Wood River Valley is currently
sourced from coal which is climate disruptive and imported from other states.
Building another power line from Hailey to Ketchum might insure us with a
redundant line and it would also assure continued supply of electricity from
coal. A renewed interest in nuclear energy could be a future source for our
electrical power, electricity that the public would pay for twice --in taxes to
pay for federal loan guarantees necessary for the development of a nuclear
plant and in the rate consumers pay IPCo. There are alternatives. Our
community has an opportunity to explore abundant natural resources
wind, solar, geothermal and biomass to provide a sustainable and secure
means of producing renewable energy and energy security. Money spent on
local energy stays in the community tax base as can be seen from Minnesota
to Denmark to Germany. Communities and countries developing renewable
energy and manufacturing parts for the energy technology of the future are
seeing the seeds of strength in their economy in a time of profound economic
uncertainty. In the preparation of this study the following question has been
asked: "What if we don't develop the technology of the future?" A response
is that we have already crossed the threshold of certainly the biggest pivotal
moment in technological history. Not only is sheer human ingenuity being
challenged to create the new technology, but simultaneously our very
survival is dependent upon it. So, logically, if we don't succeed, it really
won't make any difference if we have built another power line or not. Our
commitment as a community involves making every effort to create not only
a sustainable, but a responsible energy future. To this end, the Dynamic
Energy Systems Institute and the Environmental Resource Center have
merged to create a strategic vision for a community-wide energy
transformation.