20170623Jonas Rebuttal.pdf

Matthew A. Johnson (ISB #7789)
Wm. F. Gigray,III (ISB #1435)
Wurre PersRsoN GrcRev &Nrcnols, P.A.
5700 East Franklin Road, Suite 200
Nampa, Idaho 83687
Office: [phone]
Fax: [phone]
mj ohnson@whitepeterson. com
Attorneys for Intervenor: City of Ketchum
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY TO CONSTRUCT SYSTEM
IMPROVEMENTS FOR WOOD RIVER VALLEY
CUSTOMERS
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CASE NO. IPC.E.16-28
CITY OF KETCHUM
REBUTTAL TESTIMONY OF
MAYOR NINA JONAS
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I Q. Please state your name and office within the City of Ketchum.
2 A. My name is Nina Jonas. I currently serve as the Mayor of the City of Ketchum. I
3 was elected as Mayor in 2013 and prior to that served on the City Council from 2009-2013.
4 Sustainability and energy efficiency have been important parts of my leadership platform and
5 efforts at the City.
6 a. What is the purpose of your rebuttal testimony?
1 A. My rebuttal testimony will clarify the position and concerns of the City of
8 Ketchum with respect to items raised in direct testimony. I will also respond to direct testimony
9 related to the issue of whether Idaho Power has appropriately and adequately evaluated
10 alternatives in this matter. I will also respond to arguments raised in direct testimony related to
I I burdening municipalities with the costs of the proposal.
12 a. What are the City of Ketchumf s interests and concerns in this proceeding?
KETCHUM REBUTTAL TESTIMONY OF MAYORNINA JONAS- I
I A. The City of Ketchum ("City") is concemed with issues in the proposal of Idaho
2 Power Company ("Company") as related to protecting land usage, scenic values, and the unique
3 nature of the area. Additionally, the City joins in the concerns of other intervenors in this matter,
4 such as in the direct testimony of Michael Heckler, related to the Company's insufficient
5 consideration and review of alternatives to a redundant transmission line. The City has formed
6 an advisory committee known as the Ketchum Energy Advisory Committee ("KEAC")
7 specifically to advise the City on energy issues with a particular focus on striving toward
8 increased use of renewable energy, conservation, and efficiency. Resolution 14-005 of the City
9 of Ketchum specifically identifies a purpose of forming the KEAC is to reduce the carbon
l0 footprint of the community and become a greener community.
I I To that end, the City and KEAC have focused on evaluating new energy technologies and
12 methods of promoting energy efficiency to reduce the need for more resource-intensive energy
13 production and distribution. The City is quite interested in this proceeding for the purpose of
14 making sure the Company does not simply answer every energy question with a proposal to
15 build more "sticks and wires," but instead conduct a true consideration of alternatives. The City
16 joins with the interest of intervenors such as the Sierra Club of Idaho in questioning whether the
17 Company has truly evaluated and considered alternatives and feasibility costs that can achieve
l8 goals of resiliency and redundancy without simply reverting to building more lines.
19 a. Does the City believe the Company has adequately and appropriately
20 considered alternatives to a redundant transmission line?
2l A. No. The City does not believe that the Company has appropriately addressed or
22 investigated a true cost-benefit analysis of alternatives, including consideration of local
23 generation and micro-grid altematives. The City disputes the Company's contention that such
KETCHUM REBUTTAL TESTIMONY OF MAYORNINA JONAS- 2
I alternatives would "greatly exceed the cost of the second transmission line."l
2 The City has previously commented as to the need for more details and independent
3 analysis of reliability via local alternatives.2 An analysis of cost-effective solutions needs to take
4 into account not just immediate needs but future trends and adaptability to more contemporary
5 approaches to energy production and distribution. Better grid integration, accommodation for
6 growing local generation trends, and consideration of storage deserve a true independent analysis
7 as these options become more common and more cost-effective. The City has previously
8 commented on such and provided a potential proposal for such an analysis.3 Those comments
9 and proposal are hereby referenced and reincorporated by this testimony. This need for an
l0 independent analysis continues to be overlooked by the Company and is overlooked or
1l summarily dismissed without argument in the direct testimony of Company representatives.
12 Additionally, the testimony of IPUC staff engineer Mike Morrison recommends against a
13 redundant transmission line as an immediate need, instead recommending reconstruction of the
14 existing line and use of a temporary line.a This further indicates that there need not be a rush to
15 dismiss alternatives without independent analysis or for Idaho Power to significantly invest in a
16 less than compelling line construction that is unnecessary in the present and not designed to
17 accommodate the future. Technological changes require better analysis of alternatives than has
l8 been provided by the Company in this matter.
19 The City of Ketchum concurs and supports the assertion of Mr. Heckler in his direct
20 testimony: "We believe that a more robust consideration of alternatives is in the public interest
2l and that a combination of a rebuilt line along the existing right-of-way with some grid edge
'Application at I L
2 City of Ketchum Comment Letter, dated Oct. 4,2016, already on file in this matter
'Id.4 uoRRlSoN DI at 3 and22.
KETCHUM REBUTTAL TESTIMONY OF MAYORNINA JONAS- 3
1 resource alternatives can provide excellent resiliency at a lower cost . . ."5
2 Q. Does the City support the Company's stated goal of increased reliability?
3 A. Yes, the City shares in the concerns and goals related to increasing energy
4 reliability, as well as energy efficiency. However Mr. Heckler in his testimony outlines how the
5 Company has conflated reliability with redundancy, thus skipping over consideration of
6 alternatives to a redundant line. This matches with the City's concem that the Company has been
7 in a rush to judgment on this matter. The City's perception is that the Company has jumped
8 straight to constructing a redundant line, while ignoring the record of reliability on the existing
9 line and the likelihood that reconstruction with a temporary line more cost-effectively achieves
10 the needed reliability. As Mr. Morrison's IPUC staff testimony attests, this reconstruction option
11 is more cost-effective while the City also sees that option as having the benefit of not
12 overspending on an investment into traditional infrastructure that may be ill-suited to handle and
13 address reliability and efficiency in relation to more contemporary energy technology.
14 a. How does energy efficiency play into the goals of the City?
15 A. In forming KEAC the City specifically included pursuing and promoting energy
16 efficiency as a purpose and goal. These energy efficiency goals contrast with the Company's
17 portrayal of rising demand in this area. Additionally, Mr. Heckler's testimony shows problems
t 8 with the Company's assumptions and portrayals with respect to population growth, outage
19 events, and load demand. Again, the City believes the Company has speculated on such
20 projections in such a manner as to derive a desired result, rather than in conducting a true
2l analysis. The victim of such speculation is again a discounting of alternatives and a rush to
22 overbuilding of sticks and wires, rather than evaluation of cost efficiency and technological
23 adaptability for longer term future reliability and efficiency.
t HECI<LBR DI at l, lines 12-16.
KETCHUM REBUTTAL TESTIMONY OF MAYORNINA JONAS-4
I The City concurs with the testimony of Mr. Heckler that these concerns about
2 projections, values, and technology warrant consideration of a technical review committee
3 approach. The standard objection that such a process lengthens the time required is mitigated by
4 IPUC staffs findings and recommendation that the existing line is more reliable than portrayed
5 by the Company. The City and KEAC would be interested in participating in such a technical
6 review committee as such goes directly to the purposes and expertise for which the KEAC was
7 formed.
8 Q. How would the City like to respond to the assertions about charging
9 undergrounding incremental costs completely to the local communities?
l0 A. The City understands that there are options to direct billing to affected rate payers
1l by line item to address a local community pressing for more costly options for purposes like
12 aesthetics. However, the City feels that undergrounding has been over-portrayed as purely an
13 aesthetics issue. Insuffrcient attention has been paid to health, safety, and economic concems.
14 Engineering various overhead lines will not only impact the aesthetics and visibility within the
15 Ketchum community, but poses safety risks and creates burdens in an area where development
16 already is complicated due to space constraints. Aesthetics also become more economically
17 significant in an area where the economy is heavily reliant on tourism and a certain atmosphere.
l8 Furthermore, undergrounding seems to provide practical benefits to address many of the weather
l9 and nature-related concerns that have been raised with the existing line.
20 The City also joins in the concerns raised in Mr. Heckler's testimony that apportionment
21 of costs onto the local communities is also irresponsible at this time when there are significant
22 concerns about cost methodology. There are disputes between the Company, staff, and
23 intervenors with respect to calculation of such costs and even what should be the appropriate
KETCHUM REBUTTAL TESTIMONY OF MAYORNINA JONAS- 5
I base case. These technical issues related to cost deserve funher review and analysis before
2 beginning to order significant costs to be borne by the local communities.
3 Q. What are the City's concerns with respect to the testimony of Cox
4 Communication representatives?
5 Staff and intervenor teptimony contradicts the testimony of Mr. Stull of Cox
6 Communication that the Company requires "badly needed redundant facilities." My testimony
7 already references the problems with a focus purely on redundancy, particularly as proposed by
8 the Company, and raising questions as to a judgment of "badly needed."
9 The City understands how co-location may be desirable. However the City does not
l0 support overbuilding of redundant lines or overbuilding on a repair of the existing line any more
1 I than absolutely necessary to accommodate existing services on the poles. Heightening of poles
12 should be restricted to a minimum to preserve the character of these communities
13 Additionally, issues pertaining to co-location should be of lower priority until the
14 multitude of technical review concems are addressed.
l5 a. Please summarize your testimony on behalf of the City.
16 A. The City sees significant differences of analysis and recommendations between
17 the testimony of the Company, staff, and intervenors as to actual need in this matter. Those
18 differences need resolution via technical review; particularly where such technical review
19 provides a better avenue to more fully and independent evaluate alternatives and changing
20 technologies that better match local priorities.
2l The City supports more sophisticated analysis of technological advancement and a
22 reluctance to rush into overbuilding traditional infrastructure just because that is the way it has
23 been done before.
KETCHUM REBUTTAL TESTIMONY OF MAYORNINA JONAS- 6
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The City accepts that some level of local responsibility for incremental costs to address
purely local concerns may be necessary, but believes better analysis of such cost alternatives and
actual needed construction is necessary before imposing such.
a. Does that conclude your testimony at this time?
A. Yes.
Dated thrs'7-3d. day of June,2017
WHITE PETERSON
Matthew A. Johnson
Attorneys for City of Ketchum
KETCHUM REBUTTAL TESTIMONY OF MAYORNINA JONAS. T
CERTIFICATE OF SERVICE
I hereby certify that on this N day of June,20l7, I caused to be served a true and
correct copy of the foregoing document by the method indicated below to the following:
Donovan E. Walker
Tim Tatum
Idaho Power Company
l22l W.Idaho St.
PO Box 70
Boise, Idaho 83707 -0070 L/
Daphne Hu ang
Camille Christen
Deputy Attomeys General
Idaho Public Utilities Commission
472W. Washington
PO Box 83720
Boise, Idaho 83720-007 4
t
Peter J. Richardson
Richardson Adams, PLLC
515 N.27'h St.
PO Box 7218
Boise,Idaho 83702
Kiki Leslie A. Tedwell
300 Let'er Buck Rd.
Hailey,Idaho 83333
Kelse y Jae Nunez
Kelsey Jae Nunez, LLC
920 N. Clover Dr.
Boise,Idaho 83703
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Email : dwalker@idahopower. com
dockets@idahopower. com
ttatum@idahopower. com
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KETCHUM REBUTTAL TESTIMONY OF MAYORNINA JONAS- 8
Michael He ckler
3606 N. Prospect Way
Garden City, Idaho 83714
Zack Waterman
Sierra Club
Be njamin J. Otto
Idaho Conservation League
710 N. Sixth St.
Boise,Idaho 83702
L aura Midgley
231 Valley Club Drive
Hailey,Idaho 83333
C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock St., Ste. 900
PO Box 2900
Boise,Idaho 83701
Gre gory M. Adams
Richardson Adams, PLLC
515 N. 27th St.
PO Box 7218
Boise,ldaho 83702
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tr
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WHITE ON
jpll:\I4ork\KKetchum, City of 24892Vdaho Power-ll/ood River Valley CPNC .?43\Rebuttal Testimony of Mayor Jonas 6-23-17.doc
KETCHUM REBUTTAL TESTIMONY OF MAYOR NINA JONAS- 9