20170619Comment.PDF

IDAHO ?ZEC2VED
CONSERVATION
LEAGUE
208.345.6933•P0 Box 8,Boise,ID 83702 v.idahoconseon.org :
Idaho Public Utilities Commission June 19,2017
472 W Washington St.
Boise,ID 83702
Re:IPC-E-16-28 Idaho Power Request for a CPCN for Wood River Valley
Dear Commissioners:
The Idaho Conservation League (ICL)recommends the Commission deny Idaho Power’s
request for a Certificate of Public Convenience and Necessity to build a redundant 138 kv
transmission line in the Wood River Valley.We have reviewed the materials in this case,
along with the Idaho Power Integrated Resource Plan and Demand Side Management
reports.Based in this review,we agree with the PUC Staff the Company has not justified
the need for a fully redundant 138 kv transmission line.As more fully explained below,we
recommend the Commission:
1.To address reliability,grant Idaho Power authority to rebuild the existing line
138 kv,using a temporary back up line.
2.To address adequacy,direct Idaho Power to work with local stakeholders to
collaboratively implement cost-effective conservation measures and other local
energy security efforts.
Reliable Service
The current 138 kv transmission line connecting the upper Wood River Valley to
the Hailey substation has an exemplary service record.ICL reviewed the record in this
docket,particularly Idaho PUC Staff Witness Morrison pages 9—13 and Sierra Club
Witness Heckler pages 8-12,and see the current line has experienced 5 unplanned outages
ever.The major outage that occurred in the winter of 2009 was caused by a failure in a
wholly different part of the electric system.The current line has the potential to continue
to provide reliable service for decades ahead.
IPC-E-16-28 1 June 19,2017
ICL Comment
ICL acknowledges that Idaho Power has a duty to provide reliable and adequate
service in a cost effective manner.Our review of the record in the case indicates the best
way to meet this duty is to provide reliable service by rebuilding the existing 138 kv line
and provide adequate service by working with stakeholders to implement cost effective
conservation programs in the project area.
Respectfully submitted this 19th day of June 2017,
/7
Benjamin J.Otto
Idaho Conservation League
Cc:
Idaho Power
Donovan E.Walker [e-mail]
Tim Tatum [e-mail]
[e-mail]
Sierra Club
Kelsey Jae Nunez [e-mail]
Michael Heckler [e-mail]
Zack Waterman [e-mail]
City of Ketchum
Matthew A Johnson [e-mail]
CoxCom LLC
C.Tom Arkoosh [e-mail]
Kiki Leslie A Tidwell
Peter J.Richardson [e-mail]
Kiki Leslie A Tidweil [e-mail]
Rolling Rock Properties,LLC;Roffing Rock Properties #2 LLC
Gregory M.Adams [e-mail]
Laura Midgley [e-mail]
IPC-E-16-28 3 June 19,2017
ICL Comment