20170505Heckler Direct.pdf

i-.:aft11trni '.1 -'..- *- l '. L L.,
l:il;;,:,T -5 Pii h: lBKelsey Jae Nunez, fSB No. 7899
Kelsey Jae Nunez LLC
920 N. Clover Dr.
Boise, ID 83703
208.391..296L
kelseyG kelseyl aenunez . com
Attorney for ldaho Sierra Club
BEFORE THE IDAHO PUBLIC UTILITIES COMM]SSION
IN THE MATTER OF IDAHO POWER
COMPANY' S APPLICATION EOR
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR WOOD RIVER
VALLEY
CASE NO. IPC-E-I6_28
IDAHO SIERRA CLUB
DIRECT TESTIMONY
OE
MICHAEL HECK]-,,ER
1 Q. Ilhat is the Idaho Sierra Club's interest in this
2 proceeding?
3 A. While this docket raises substantial- issues
4 rel-ated to l-and use and scenic values, the interest of the Idaho
5 Sierra Cl-ub ("Sierra CIub") primarily focuses on the technical-
6 and financial aspects of the Idaho Power Company ("Company")
7 proposal . Ir{e chose to intervene and testify because the Company
B has not provided an adequate review of rel-evant costs and
9 technical al-ternatives to their proposed redundanL transmission
10 line, and as such the proposal is not consistent wlth what the
11 Sierra Club sees as the public interest.
L2 We bel-ieve that a more robust consideration of a]ternati-ves
13 is in the public interest and that a combination of a rebuilt
!4 line along the existing right-of-way with some grid edge resource
15 al-ternatives can provide excell-ent resiliency at a l-ower cost
16 than the proposed redundant transmission sofution. Such
L7 resiliency in the North Wood River VaIIey ('NWRV') may help
18 facil-itate the City of Ketchum's ability to realize.their c1ean
19 energy objectives, which are j-n alignment with Sierra Club's
20 efforts to promote the decarbonization of the electric sector.
2l A. Please surnmarize Sierra Club's concerns with the
22 proposal.
23 A. The Company seeks an order to "construct
24 improvements to j-ts el-ectric transmission system to secure
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adequate service to its customers. "l We agree some improvements
to the NWRV transmissi-on system are likely warranted, but the
Company has failed to show that building an additional
transmission Iine is the most cost-effective sofution available.
The Company has been working, at l-east. intermitLently, on
building an additj-onal transmission line from Hailey to Ketchum
for 44 years. Technol-ogy has changed radically during the last
four decades, yet the Company has continued to push ahead with
their same preferred sofut.i-on from 1973. We beLieve there are now
alternatives that coul-d provide a higher l-evel of benefits for
al-1 customers of the Company whil-e ensuring adequate and reliable
service in the NWRV, but those have not yet been properly
analyzed.
While the Sierra Club is willing to concede that the
now requires complete
think the information in this docket
"aging and
is adequate to support the Company's proposal to build an
additional transmission line. Eurther, we do not bel-ieve that
building a redundant transmission line, with a 70 to 80-year
useful- Iife, is a cost-effective technical- solution or a solution
that addresses more than a narrow portion of the NWRV delivery
system.
existing l-ine is
reconstr:ucLion"z ,we do not
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Applicatj-on at 1
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IDAHO SIERRA CLUB
Application at 76.
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A. I{try do you think the proposal doeE not include
adequate information?
A. The proposal does not contain enough re.l-evant
information about alternative solutions to reliability problems
in this relatively remote and mountaj-nous portion of the
Company's service territory. As such, it precludes an informed
decision on how to best ensure reliable and adequate service to
the NWRV. Sierra Club acknow.l-edges that on technlcal- questions
Iike reliability, the Commission often defers to the Company, but
we are operating in a time of rapid technofogi-caI change in the
electric utility industry. A thorough analysis of al-ternatives is
more important now than it was even a decade ago, and,becau.se the
proposal does not incl-ude an adequately completed analysis, gqch
deference is not appropriate at t.his time.
a. Please describe your roJ.e with the Siera CIub
and a sunmary of your relevant e:<perience with the issues in this
proceeding.
A. I am the Chair of the Idaho Sierra Cl-ub's Energy
Committee. Prior to my retirement in 2012, I had multiple
professional rol-es. While I realize that the decisions made by a
public body such as this Commission must balance far more than
the primarily commercial- values I addressed in the private
sect.or, during my career I helped resofve many matters with cost
and technical complexity similar to the issues raised in this
docket.
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]DAHO SIERRA CLUB
1 At SeaEirst Bank, I administered budgeting and profit plan
2 performance measurement for the bank. At Boeing, among other
3 things, I managed budgeting, install-ation and operation of
4 computing hardware in a large-scale scientific data cent.er. I
5 have managed multiple procurements and projects with contract
5 values measured in tens and hundreds of mil-l-ions of dollars.
1 My academic traininq lncludes bachel-ors, masters and
B doctoral level degrees in accounting, finance and law,
9 respectively.
10 Eor approximately a decade beginning in 2002, I worked as a
11 wind farm developer. I have been an active participant in every
12 Idaho Power Company fntegrated Resource Pfanning process from
13 2OO2 through 2017 and on multiple instances have'provided
14 comments/testimony before this Commission.
15 I appreciate the opportunity t.o submit testimony in this
76 docket.
L'7 RELIABILITY
18 A. Given the Company's duty to provide adequate and
19 reliable service to customers in the NWRV, what concerns does
20 Sierra CJ.ub have with how matters related to reliability have
21 been addressed in this docket?
22 A. Sierra Club accepts and completely supports the
23 need to provide rel-iable electric service to customers i-n the
24 NWRV. We are concerned that errors and mj-srepresentations have
25 occurred in the terminology the Company has employed and in the
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scope of review they have conducted on matters related to
continuing to provide rel-iabl-e service. These errors and
mj-srepresentati-ons take three forms:
1. A confusion of the concepts related to re1iable,
redundant and proximate.
2. An insuf f icient review of the "rel- j-ability" of
the existing WDRI-KCHM line.
3. A resul-tant proposaf to over-bui1d a portion of
the NWRV delivery system.
A. Can you explain your perspective on the
relationship between "reliability" and "redundancy" as presented
in the Application?
. A. Mr. AngeIJ- characterizes the proposed redundant
transmissj-on l-ine as a need, adding that it would al-so allow for
load growth. and facilitate rebuilding of the existing line.3
Sierra Club is concerned with how the Company confl-ates
"reliability" and "redundancy" and "redundancy" with "physical
proximity".
Constructing redundant transmi-ssion lines is but one method
for enhancing refiable service. but redundancy is
itself. Rel-iable service is the need. Transmission
not the need
i-s one way to
improve transmission reliability, and redundant transmission is
one way to provide transmission. The Company's characterization
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t See Angel1 aL 2, 27-23.
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of a redundant transmission l-ine into the NVIRV as a need
mischaracterizes one potenti-al sol-ution for providing future
reliable service with the need itself.
O. Can you explain why it is problematic to
miEcharacterize redundancy as a need instead of one potential
solution?
A. Mischaracterizing redundancy as a need has
shifted the focus of analysis onto the detail-s of designing and
locating the redundant line instead of on a Lhorough and
necessary review of the measure of reliable service needed in the
NWRV. This shift has precl-uded an adequate analysis of
al-ternati-ve methods for meeting the rel-iability standard.
A. Can you explain your concerns with how the
Company conflated the concepts of physical. proximity and
redundancy?
A. When Mr. Ange11 explained why the Company had not
proposed accessing the KCHM substation over the same route the
existing l-ine uses running from the EKHN substation, he faulted
that route as failing the "need" for redundancy. He argued that
where the proposed new line woul-d run near the existing line
their proximity would raise the risk that a single event could
incapacitate both lines.n We have two major concerns that fol-l-ow
from this fine of argument.
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]DAHO S]ERRA CLUB
Angell at 29.
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First, the Company's proposed rout.e is
stated problem of having two l-ines being in
not free from the
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close proximity of
each other. The proposed line woul-d cross the existing WDRI-KCHM
l-eave their commonIine within a quarter mil-e of where both lines
source at the WDRI substation. Moreover, there are never more
than a few hundred yards separating the two l-ines for the first
few mil-es of their rouLes north of WDRI (unt.il they are some ways
north of Ohio Gul-ch Road) . s
Second, and perhaps more fundamentally, the WDRI substatj-on
is still a single point of faifure. The proposed new redundant
line would originate from the same substation as the existing
line. Because both lines are dependent upon the operational
integrity of t[r'at single ,substation, the proposed redundant line
wil-I not provide an i.ndependent source o{ energy as the Company
purports.5
A. Please elaborate on the issue of the I{DRI
substation being a single point of failure.
A. The Company's proposed redundant l-ine could not
provide any power to NWRV if an outage event affected the WDRI
substation. The 70O-minute outage on December 24,2009 was due to
s AngeII, Exhibit 4
6 Direct Testimony of Michael J. Youngblood, Exhibit ! aL 2
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1 loss of electric supply to the VIDRI substation.'That was one of
2 Lwo l-ine outages the Company l-isted for the WDRI-KCHM l-ine that
were not caused by failures on any portion of the existing line
and woufd not have been mitlgated by redundant l-ines from WDRI
because no power was getting to WDRI substation. The second was
46-minute outage t.hat occurred on June 4, 2014 was caused by
broken cross arms and affected 20,228 customers.u Given that
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there are approxj-matel-y 9,700 customers
that this ouLage must have i-mpacted the
substation or south.
in the NWRVe, it foll-ows
system at the WDRI
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A. ff we re-characterize the proposed redundant line
as just one potential solution to the need for reliability, as
opposed to the need itself, can you please e:<pIain your concerns
with selecting the redundant line as the solution?
A.- Yes. but first I would tike to put the second
analysis deficiency - an insufficient review of the reliability
of the existing WDRI-KCHM l-ine into a new, cl-earer context.
A. PLease elaborate.
' Idaho Power Company's Response to Tidwel-l-'s Request for
Production No. 3f, Exhibit No. 301.
8 Idaho Power Company's Response to Staff's Request for
Production No. B, Exhibit 302.
e AngeII at 3.
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A. The history of the existing Iine's rel-iability suggests
that a rebuilt line could also provide excellent reliability.
Prj-or to the Company requesting that its CPCN from 1973 be
cancelled, they retained Engineering Data Management, Inc. (*EDM')
to review the structural condition and electrical reliability of
the WDRI-KCHM l-ine and analyze its conditlon.'o EDM's 1993
El-ectrical Rel-iabilit.y Study analyzed the total of three minutes
of outages from 1980 to 1993 and concl-uded:
"The outage records speak for themsel-ves. Two outages in
the past fourteen years for a tota.l- duration of three
minutes incl-ude one weather related outage, at.tributed to
heavy snow and one switching outage. The low incidence oflightning in this area combined with the line's proximity
to the mountains and relatively good condition of theentire power line give the Wood River to Ketchum 138kV
Transmission Line an operating record that is practically
unsurpassable. "ll
a Can you show the sustained outage history
graphically?
I created the fol-lowing figure showing outage
history with data provided by the Company:
10 fdaho Power Company's Response to Tidwell's Request for
Production No. 18, Attachment 2 (the Electrical- Data
Management, Inc.'s Electrical Reliability Study) , pages 1-3 as
Exhibit 303.
11 Electrical Data Management, Inc.'s ELectrical Reliability
HECKLER, DI 9
IDAHO SIERRA CLUB
A
Study at 3, Exhibit 303.
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The Company was..not abl-e to document any outages before
L995, although EDM moved that record back to 1980. Based on the
data provided, between 1980 and 2016 the J-j-ne experienced only
3.3 hours of sustained unplanned outages. i2 3.3 hours in 35
years. If we divide 3.3 by the tota"l- number of hours in those 35
years it implles that over the three and half decades from the
first Reagan election to the present, the line has not
experienced an outage 99.999% of the time.
During that 3S-year period, there were another 15.3 hours
of planned outages for maintenance. The planned outages were done
72 Id.aho Power Company's Response to TidweII's Request for
Product.ion No. 13, Attachment l, Exhibit 304.
HECKLER, DI 1O
]DAHO SIERRA CLUB
The WDRITKCHM line has been in use for 55 years and has experienced fcur
unplanned sustained outages - for a total duration of 3.3 hours over 55
years. Since 1,995 the line has been taken down for an additional 15.3
hours for planned (maintenance) outages
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during off-season (May, September, or October) 13 and at times
when total- KCHM and EKHN l-oad were less than 15MWs.la
The Company's records show that outages in December or
January have tota1ed only 10 minutesls, which is far less than
Lhe 24-hour time period the Company used as a requirement in its
analysis of alt.ernatives.16
Given this history of relatively rare, short-duration
unplanned outages that show no seasonal- pattern, combined with an
operating history the Company's contractor characterized as
"practically unsurpassabfe"lT, there is no reason to believe that
a newly rebuil-t transmission line cannot provide the same
exceptional reliability, if not better.
Exceptional re.Iiability is even more 1ike1y 'given the
Company's plans to reconstruct the existin.g line with steel- poles
that will have a betler structural capacity and be able to
13 Exhibit 304.
74 Idaho Power Company's Response to Idaho Sierra CIub's First
Request for Production No. B, Exhibit 305.
15 Exhibit 304.
16 Anqell at 1,4.
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1' Exhibit 303 at 2
l- withstand some threats better than the wood poles currently in
2 use.18
3 Q. Moving back to your concern with the redundant
4 line option, you mentioned that the redundant line would lead to
5 "over-building" a portion of the IIYIRV electric delivery system.
6 What is the nature of your concern?
1 A. Let me respond first to the issues related to
B analyzLnq lust a "portion" of the NWRV delivery system before
9 covering concerns related to "over-bui1ding".
10 As I described above, aff energy that would be available
11 for transmission across the proposed redundant line comes via the
72 WDRI substation. Similarly, all customers in the affected portion
1.3 of the NWRV get their service via distribution fines running from
14 the KCHM or EKHN substations. Upgrading the linkages between WDRI
15 and KCHM/nXum does noL protect customers from outages arlsing on
16 eit.her end of those transmission links (those ends being at the
L7 WDRI substation or on a distribution li-ne).
18 Regarding over-building a portion of the system, it was
19 described above that the exi-sting WDRI-KCHM line has proved
20 99.999% refiabfe against unplanned outages. In the Company's
27 Response to Tidwell's Request for Production No. 51, Mr. Angell
22 stated that shou.l-d the proposed redundant line be buil-t the
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24 18 See Idaho Power Company's Response to Idaho Sierra Cfub's
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25 Request for Production No. 2, Exhibit 306
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probability of concurrent outages on two 138kV lines between the
WDRI and KCHM substations would rise to one outage in 3,000
years.le It is not clear that there is much of a practical,
significant difference between 99.9992 reliable and one outage in
3,000 years, or that this supposed reliability "improvement" can
justify the costs proposed by the Application.
ADEQUACY
A. Please sumnarize your understanding of the
Company's ar!trument that a redundant line is needed to accormodate
future load growth.
A. As I read the Company's application and
supporting material-s, I can summarize.the argument. as.follows:
One of the justiflcations for building a redundant Iine is based
on assumptions about future load growth in the NWRV.
Specifically, in both the 2007 and 2011 Wood River Va1ley
el-ectric p1ans, Ioad growth is pro;ected Lo grow to 8OMW served
from the Ketchum substation and 40MWs served from the El-khorn
substation'o. Since the existing line has a capacity of 12OMWs,
it is said that such future Ioad growth will require some safety
margin in transmission capacity and the redundant fine is
partially justified as a source of additional capaclty.
1e Idaho Power Company's Response to Tidwell's Request for
Production No. 51, Exhibit 307.
20 Ange11 Exhibit 2, Appendix C at 7-8.
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IDAHO SIERRA CLUB
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A. Do you agree with that assessment?
A. No.
A. PLease explain why not.
A. Currently, peak l-oads rise t.o about 50% of the
existing line's 12OMW capacity and average loads are, of course,
lower. History doesn't support the Company's projections of
future'l-oad growth and cal-l-s lnto question the methodology used
to develop those projections.
Both the 2007 and 2011 versions of the Wood River Valley
Electric Plan forecast that l-oads wil-l- more than triple over the
lifespan of the proposed redundant transmission l-ine. One of the
methods used to forecast t.hat growth was based on population
growth projections provided by John Church, Presid.ent of Idaho
Economics.
Looking at the 2006 popul.ation of Bl-aine County north of
Timmerman Hill up to SNRA headquarters (21,600 people using a
winter peak of 99.5MWs), Church and the Company projected this
populatlon to grow at a compound annual rate of 1.8% per year.
That growth rate implied that by 2080, the population of t.he area
would be 76,L61. Church then assumed that each of the 76,767
persons would demand an average of 4.2kW. Multiplying 16,161
people by 4.2kW per person yields "about 320MW for total- Wood
River VaIley area buildout l-oad"21. The Company subdivided that
HECKLER, DI 14
IDAHO SIERRA CLUB
21 Ange11 Exhibit 2, Appendix B at 2
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projected 32OMWs by substation, allocating 200MWs to substations
further south and forecasting 80MWs for Ketchum and 40MWs for
Elkhorn substation l-oad.s.22
A. I{hat is the fLaw you see in this analysis?
A. Peak winter load in 7994-7995 was 55.5 MW.23 This
past winter it was 55.8MV\i. The following graph displays peak
l-oads on the WDRI-KCHM l-ine this century.2a It clearly shows that
in the l-ast 10 years, growth is not compounding at the rate
stated in the 2007 and 2011 plans:
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22 See AngeII Exhibit 2, Appendix C at 7-8.
23 Staff's Request for Productj-on to Idaho Power Company No.
\6, Exhibit 308.
24 The data in the graph
Power Company's Response
No. 1, Exhj-bit 309, and
were provided in Table 7.1 of Idaho
to Tidwe11's Request for Production
Idaho Power Company's Response to
18, ExhibitIdaho Sierra CIub's Request for Production No.
310.
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First, while load growth may have looked to
been largely flat in the
been the case throughout
be on an upw-ard
NWRV sinc'e the '
most of t.he
slope in 2006,
2008 recession
load has
(as has
Company'scountry). The
that reality.
Second,
2001 /2077 analyses do not ackhowledge
just as more efficient electric-powered products
(tights, motors, computers, etc. ) have upset traditional- trends
in el-ectricity load growth, policy decisions by states and
Ioca.l-ities limit the l-ikel-ihood of rapid l-oad growth in the
future. Eor example, the City of Ketchum's 2015 Energy
HECKLER, D] 16
IDAHO SIERRA CLUB
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Conservation Goafs include a city-wide target of 50% per capita
reductions in energy use by 2030.2s
As Ketchum residents represent the majority of the el-ectric
l-oad in the NWRV area'u, their actions in reducing energy
consumption per capita are relevant to any projected future load
growth analysis. Combining reduced consumption policies with high
l-ocal- property prices that constrain extensive new development in
the area, the Company's high annual compound population growth
estimates are unrealistic and make the Company's NWRV l-oad
projections suspect.
In sum, the 12OMW capacity of the existing WDRI-KCHM l-ine
is likely to be adequate to serve l-ocal- load into the foreseeable
futur.e
9. Even if there doesn't appear to be substantial
![9tRV load growth in the near future, what about the Company's
projections out to 2080?
A. Projecting load growth over the next 60 years is
speculative in and of itself, and is an inappropriate basis for
justifying building an expensive, long-Iived asset using today's
25 See City of
Establishment
Ketchum Resolution No . 75-0L2, Regarding
of Energy Conservation Goals for the City of
Ketchum (March 10, 20L5), Exhibit 311.
26 Idaho Power Company's Response to ldaho Sierra Club's
Request for Production No . 13, Exhibit 312.
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conventional- transmission technology. The rapid technofogical
development taking place in the utility sector, especially rapid
advances in options for improving rel-iability with "grid edge"
resources", makes it likely that even j-f the NWRV experiences
substantial load growth Iater in this century, other al-ternative
solut.ions wil-l be available at that time to more cost effectively
address those requi-rements.
9. Putting aside the conversation about distributed
resources for now, do you see any other near-term alternatives
for increasing capacity on the system without building a
redundant line?
A. Perhaps the rebuilt existing line could be
constructed with a larger conductor that would j-ncrease iLs
capacity.
AI{ALYSIS DEFICIENCIES
A. PleaEe describe your concerns with the Company's
analysis of alternative generation resources.
A. My general concern is that the analysis was not
conducted objectively. During my career, I wit.nessed multiple
27 See Elaine WiIliams, "Knowledge Gained As Power Conserved",
The Lewiston Tribune (April 9, 20L7) , avail-abl-e at
http: / /www. spokesman. com/sLories /2071 / apr/ 09/knowledge-gained-
HECKLER, D] 18
]DAHO SIERRA CLUB
as-power-conserved/, Exhibit 313
1 instances where a technical- group would attempt to justify
2 selection of a particul-ar computer hardware or software supplier
3 by constructing their analysis j-n a way that only that one
4 supplier coul-d meet. This docket strikes me as another instance
5 of justification substituting for anal-ysis.
6 Additional- information, beyond what the Company has
7 provided to date, is necessary to conc.l-ude that a redundant line
B is needed or that redundancy is the l-owest-cost or even a cost-
9 effective method for supplying reliability requirements. To
10 determine that. an alternative provides the l-owest-cost solution,
11 multiple al-ternati-ves need to be properly evaluated without a
t2 predetermined outcome in mind. The analysis submi-tted with the
13 Application is insufficient to support either concfusion.
L4 A. Please elaborate on the insufficiencies in the
15 alternatives analysis
16 A. The Company used multiple inappropriate
l7 techniques in their purported afternatives analysis including:
18 . Using their redundant line proposal as basel-ine against
19 which alternatives were compared rather than comparing
20 al-ternatives against a need for reliable service;
27 o Excl-uding relevant costs from their analysis;
22 . Over estimating costs for some al-ternatives;
23 . Eail-ing to acknowledge potential synergi-es between
24 alternatives; and
25
HECKLER, DI 19
IDAHO SIERRA CLUB
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. Failing to evaluate benefits that some alternatives could
provide, focusing solely on costs rather than the
. appropriate cost/benefit standard for measurement.
I will address the fol-lowing flaws in turn: (i) wrong basel-ine;
(ii) missing cost data; (iii) wrong cost estimates; (iv) ignored
combinations; and (v) ignored benefits.
WRONG BASELINE. The hypothetical- outage conditions that the
Company used to test al-ternative resources (hereafter
"distributed energy resources" or "DERs") against were (i) 24
hour outage (ii) at the peak of winter season (iii) with a
heating l-oad driven by temperatures stayingr aL -21F for the
entire period and (iv) an assumption of a requirement to serve
al-l- load rather than just critical load during outage periods.
These timing, l-oad and duration conditions have never
appeared in reported outage history, and assessment under these
conditions
ability to
S ince
presidency,
faifure on
l-eads to misleading concl-usions about the
serve temporary system outages.
the WDRI-KCHM line was built back during
the longest documented unplanned outage
DERs,
the Kennedy
due to a
the line between WDRI and KCHM was 2 hours and 6
minutes.2s The longest outage during the December January peak
28 Idaho Power Company's Attachment 1 submltted in Response to
Tidwell's Request for Production No. 13, Exhibit 304.
HECKLER, DI 20
IDAHO SIERRA CLUB
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tourist season was 10 minutes.2e Planned maintenance outages
lasted up
shoul-der
to 8 hours, but those
season (May, September,
outages were
or October)
scheduled in the
when load was l-ess
than 15MW and were largely conducted in the middl-e of the
night.30
I am concerned with the adequacy of the results of the
assessment of the DERs. We wou.l-d have better information to
analyze if the assessment was conducted using a basel-ine t.hat
more accurately reflected actual- outage history, in duration,
Ioad, and seasonal timing.
MISSING COST DATA. The Company states that the existlng
l-ine wil-I need to be re-buil-t but did not provide cost estimates
for those activities when analyzing the cost of the redundant
line and its alternatives. Each afternative generation source was
2e The December 24, 2OO9 outage was caused south of WDRI
substation and still would have had the same effect on the
NVIRV regardless of how many transmission Iines were installed
between WDRI and KCHM substati-ons.
" As noted above, the need for several of the maintenance
outages (i.e. for wood decay and woodpecker damage) could be
mitigated by rebuil-ding the existing Iine with steel
structures, which should al-so reduce the pot.ential threat
associated with fire, avalanche or micro-burst winds.
HECKLER, DI 27
IDAHO SIERRA CLUB
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compared to just the cost of the redundant line, but not the cost
of the entire project,
existinq l-ine. Because
study does not enable a
eliminates some options
which includes the cost to rebuild the
the rebul]d cost data
true analysis of al-l
is missing, the
the al-ternatives and
from being considered.
Eor example, one basic al-ternatives analysis coul-d have
compared costs of (1) rebuilding the existinq line and adding
some back-up generation for low probability outages with (2)
building t.he proposed redundant Iine and rebuilding the exlsting
f ine. Such basic cost analysis coul-d l-ook l-ike:31
The afternative that involves using "shoo-f1y"temporary
for loca-l-Iine saves more than $25 million that could be used
31 Data from ldaho Power Company's Response to Idaho Sierra
Cl-ub's Request for Production No. 1, Exhibit 314.
HECKLER, DI 22
]DAHO S]ERRA CLUB
Proposed redundant line Rebuj-ld existingline without adding
redundanE line
Cast of
redundant line $30 million l.Iot app3-ieable
Cost to rebuildexieting J-ine
using redundant
)-ine durinq
outag:eE
$6.2 million sot, applicable
Cost eo rebuildexisting J-ine
ir:cLud5.ng costsof ternporary*'ehoo-f3y" Iine
Not applicable $9.4 mil-lion
Totals $3 6 .2 mill-ion $9.4 :nillion
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resources to cover for limited risk outages and provide benefits
general to the Company customer base at other times.
Given that total load durlng maintenance periods was less
than 15MVrls, there shoul-d be enough out of the $25 million savings
to pay for maintenance backup.32
WRONG COSTS. The cost estimates for some key alternatives
are al-so inappropriate and overstated. The Company compares
batteries that are priced at $800/kwh, but Tesl-a is currently
offering them for around $250.33 The qas turbines analyzed are
sized greater than 50MWs, for which the Company says there is not
enough fuel. The Company could have analyzed the smal-Ier and
lower cos.t reciprocating enqine units that are analyzed in their
rntegrtted Resource PIan (e.g. Wartsil-a) .3a
32 Idaho Power Company's Response to fdaho Sierra Cl-ub's Eirst
Request. for Production No. B, Exhibit 305.
33 Tesla prices for batteries without installation. With
$450/kw and declining.installation, the cost would be about
34 January !2, 2ot't Supply Side Resource Operating Inputs shows
Cost (EPCReciprocating Gas
and other Owner's
Engine at $775lkw Plant Capital
Costs). At the April 13 IRPAC meetinq,
PhiIip DeVoI said that Vfartsila has been
and suggested that some of their product
even lower.
j-n to visit recently
l-ine could be pri-ced
HECKLER, D7 23
]DAHO SIERRA CLUB
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AdditionalIy, the Company could have considered some of the
various modular diese1 generators on the market that range in
can be2MW, including mobile generators thatsize up to
transported
be utilized
througthout Lhe service territory. Such generat.ors can
during maj-ntenance of infrastructure and servicing
10
unplanned outages, while also providing support for essenLial-
services throughout the Company's service territory in the event
of emergencies.35
A 2013 FEMA press release highlights several of the
benefits these modular diesel generat.ors can provide to
communities.36 For example, the City of Seaside Heiqhts, NJ,
originally purchased and installed three 2MW diesel generators to
provid.e services during periods of peak-power demand at a cost of
$4 miIlion. When superstorm Sandy caused massive disruptions to
the grid, the city relied on these generators to power important
services in the community for 3 weeks. Unl-ike a new redundant
transmission that only would only benefit a small- portion of
35 Eor example, a company with local distribution out of
Pocatel-1o can se.l-1 a range of unconsidered alternatives:
http z / /www.qenerac .cami inciustrial/industrial-
solutions/munj-cipal#results. The graph provides a range of
315 .l3 al-ternatives based on size of generator. Exhibit
24
36 lrttps : / /www. f ema. gov,/news-release / 2013 / 0 5 / 21 /emerqencv-
11
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-comes-ashore. Exhibit 316
HECKLER, DI 24
IDAHO SIERRA CLUB
:5 generators -power-town-af t.er- sand
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resiliency in
IGNORED
ways that dupl-icative transmission
COMBINATTO]VS.The anafysis of DERs
from the false presumptions that only one source
energy can serve a system at a tj-me and that one source of energy
needs to serve the entire load at any given time. These are
artificially high standards of performance.
Because of the failure to analyze DERs in combination with
each other, the analysis provj-des incomplete conclusions about
DERs' potential. t.o temporarily meet the need during rare outages.
Eor example, a. vafuable combination that coul-d have been analyzed
but was not is some distributed battery storage and some limited
amount of local generation. The Company also neglected to analyze
15 the val-ue of other reasonable combinations of distributed
1,7 resources, incl-uding employing
backup generation and targeted
area -
existing customer owned and new
1B efficiency efforts in the NWRV
19
20 IGNORED BENEFITS. In the analysis the Company performed,
that some of the al-ternatives coul-d21,
Idaho Power customers during
the l-ine itsel-f is powered) ,
numerous benefits across the
they ignored
provi-de and
benefits is
system benefits
just looked
exceptionally rare events (assuming
these diesel- generators can provlde
service territory and increase
simply cannot.
also suffers
of alternative
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at capital costs. The comparison
understanding t.he full scope of
of
options.
storage
necessary t.o
24 Some of the evaluated alternatives, such as battery
25 or some amount of emergency generator capacity, coul-d provide
HECKLER, Dt 25
IDAHO SIERRA CLUB
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benefits to a larger portion of the public than just residents of
the NVf,RV, who would be the only beneficiaries of the redundant
l-ine.
Outages caused by icing, micro-burst winds, fire or
aval-anche are associated with specific relatively predictabfe
conditions. When a hei-ghtened threat of such an outage is
predicted, resources like storage could be charged and held ready
for backup service. At all other times the storage could be used
for purposes like l-oad shifting that provide a benefit to the
general Company customer community. Local emergency reserve
generation could provide similar benefits to the general Company
customer set. The Company's analysis failed to recognize these,
or other; beriefit streams in its eval-uatj-on.
In sum, the combined effect of these five ma3or
deficiencies is that the Company produced a record without
adequate information upon which to determine whether the proposal
is cost-effective, 1et alone the l-east cost al-ternative among the
options for providing reliable and adequate service in the NWRV.
9. Do you think the analysis of distributed energy
resource alternatives ought to be redone?
A. Yes. A decision about the best way to provide
reliable and adequate service to the NWRV cannot be made unti-l we
HECKLER, DI 26
IDAHO SIERRA CLUB
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have a true understanding of the costs and benefits for
alternatives to a redund.ant transmission 1ine.37
The Commission authorized a technical review committee in
the recent solar integration case when the parties were having a
challenging time seeing eye-to-eye on the technical details and
va]ue assessments. The issue of how to create focal resil-ience
with reliable service is complex and coul-d benefit from a team of
diverse stakeholders foll-owing a similar process.
A. Wou1d you consider such a technical review
committee to be dupticative of the CAC process?
A. No, not at al-l-. Sierra CIub acknowledges that the
Company and WRV citizens spent many hours participating in the
CAC process. We frrrt-her rrnderstand that in light of the December
24, 2009 outagesr.flWRV residents have an understandable concern
regarding a reliable power suppty. But the results of the CAC
process shoul-d be put into appropriate context.
The CAC was not composed of members who were experts on the
need for additional transmissioni CAC members provided expertise
on transmission line siting. The CAC Iimited in
and focused on the detaifs of siting
process was
a redundant Iine, and
scope
the
an 31 The Company itself acknowledges that the
23 conceptual and high-Ievel and insufficient
:4 the costs and benefits of integrating DERs
analysis was
to fully understand
into the
of 56 and 9 of 56.
HECKLER, DI 21
IDAHO SIERRA CLUB
:S transmission system. Angell, Exhibit 3 at 3
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"need" for the redundant .l-ine was presumed as part of that
process.
A. What is your understanding about the CAC's
presr:mption that the redundant line was "needed"?
A. While understandabl-e in the aftermath of the 2004
Eagle case, from the very start of the CAC process members were
encouraged to associate "new transmission" as needed for
"rel-iabl-e power". The 2007 Wood River Electrical- Plan states,
"The first step in developing the proposed solutions to the
e1ectrical needs of the Wood River Valley was to develop a Goals
Document that could be used to guide the committee's efforts to
develop and eval-uate alternati-ves. " The f irst and second of the
six goal areas in that document were: (1)"Provide reliab1e power
to the entire Wood River Valley" and (2) "Develop new
transmj-ss'ion and delivery infrastructure .as appropriaLe when
providing for current and future power needs. "38
A decade later, this direction by the Company that
"redundant transmi-ssion is needed" was more clearly outl-ined in a
Ietter to the CAC dated May 19, 2076. According to fdaho Power's
letter:
More importantly, to truly improve the rel-iabifity and
the quality of servj-ce to the North VaIIey, a second,
independent source for energy, - a second 138 kV
transmission l-ine - is required. The second line has
been needed and in various stages of planning for
approximately 30 years. Eor various reasons, primary
38 2007 Wood River Electricaf Plan at !2, Exhibit 31,1.
HECKLER, DT 28
IDAHO S]ERRA CLUB
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of which is lack of agreement upon siting a new Iine
and the visual impacts of such, Idaho Power has been
unabl-e to si-te and construct this second line into the
North Va1Iey.3e
The CAC's rol-e was not to question the need for the
redundant l-ine but to agree on its route. As f stated above, the
CAC members were potentially misJ-ead assertion t,hat a
second 138kV transmission line would
by the
provide
source of energy" rather than just
for get.ting energy from the single
shoul-d a situation arise where t.he
availabl-e.
Eurthermore, statements from
that the Company had a pattern of
providing
an "independent
a redundant method
source (the WDRI substation)
existing line woul-d not be
line was needed, thus limiting the
the Sun Valley government show
asserting tnat tne redundant
scope of analysis for NWRV
t.his proceedi-ng, made thecustomers. Ms. Tidwell, a party to
fol-Iowing production request to t.he Company, which reads in part:
The Company's Application states at page 11 that "SunVaIley stated that at the regular City Council meeting
of September 1, 2016, the counci.l- unanimousJ-y agreed
that the redundant l-ine project was necessary and
vital for its community. . ." The Mayor of the City of
Sun VaIl-ey stated at the referenced meeting that, *It
is not a vote, it is an expression of our wishes asfar as how they wil-l- tackle this project that they are
mandated to do to provide us with power. They [IdahoPowerl have decided that they need to do this [and]
HECKLER, DT 29
IDAHO SIERRA CLUB
39 Youngblood Exhj-bit 1 at 2
l-
n
3
4
5
6
1
the are askin us to think about how we want it
done
Thus, it appears that this presumption of need
significantly impacted the CAC process and l-imited the analysis
of redundancy al-ternatives that couLd also provide reliable
service to Sun Valley and the other NWRV residents.
LOCAf, V. GENERAL BENEFIT
S 9. Can you explain how the Company determined the
g costs associated with undergrounding a portion of the redundant
10 line and how the Company justifies recovering those costs from
11 all ratepayers?
L2 A. As the Company notes in their Application,
13 underground t.ransmission Iines usually cost a significant premium
L4 compared to overhead tramsmission, are more diffi-cult to service,
15 and have a shorter lifespan. The Company also explains that the
L6 NWRV community has ]ong had significant concerns over viewshed
l7 impacts and that local opposition has been a challenge for movingr
18 forward with the proposed redundant Iine.
19 The various route options described in the AppJ-ication
20 presented alternative ways to site the redundant l-ine and compare
2L
)^a0 Tidwell Request For Production to
!9, citing Clty of Sun Valley audio
2076 at hour 1:45 (emphasis added) .
Idaho Power Company No.
transcript, September 7,
Exhibit 318.
23
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HECKLER, DI 3O
IDAHO SIERRA CLUB
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undergrounding costs to a "base case" without undergrounding.
However, it is l-ess than cl-ear to me how Idaho Power concludes
that it is appropriate to charge all ratepayers for the costs
associated wi-th undergrounding. More specifically, it 1s not
clear to me that the l-owest cost "base case" was appropriately
selected or that the true costs of undergrounding - and how those
wil-l- be paid - are fu1ly understood at this time.
a.
relation
Given your answer above, what do you suggest in
to the assessment of Iocal benefits versusr the general
10 public interest?
11 A. As described above, the Sierra Club has real
L2 concerns about the presumption that redundancy is a "need" and
13 that alternatives to address rel-iability. were not properly
L4 analyzed. Both of these issues caII into question the validity of
15 the methodology used to ascertain the appropriate cost all-ocation
L6 between local and general ratepayers. As such, the cost analysis
L1 warrants further consideration prior to issuing the requested
1B CPCN.
19 CONCLUSION
/tt A. PLease sunmarize your testirnony simply.
A. The Company may prefer to build a redundant
transmission l-ine (which wil-I most likely go into rate base at
some time), but it has not. demonstrated its necessity or value to
the publ j-c interest.
2t
22
24
HECKLER, DI 31
IDAHO SIERRA CLUB
23
25
l_
2
3
4
5
6
7
8
9
The Company has been pushing for this l-ine for decades,
with recent activity ramping up since publishing the 2007 Wood
River Valley Electric Plan. Consider that 2007 is the same year
the fj-rst iPhone came out and note the astounding chanqe mobile
internet access has provided in the last decade. The electric
utility industry is afso facing a period of dramatic
technological change. Yet, the Application seeks approval to
build a 70 to 80-year asset to accommodate statistically unlikely
outages in a region that could benefit from technological
advances in distributed energy resources. It is not in the public
interest to move forward on this construction project without
understanding what refiability requirements would exist with a
rebuilt line along the existi-ng route and thoroughly'assessing
how rapi-dly improving afternative technologies. could compliment
NWRV service
A. Does this conclude your testimony for now?
A. Yes.
*****
DATED this 5th day of May, 2011.
Respectfully submitted,
10
11
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20
21,
22
23
24
Y,&nqe Niln,',
i"l
Kelsey Jae NunezAttorney for Idaho Sierra Club
HECKLER, DI 32
]DAHO SIERRA CLUB
25
CERTIFICATE OF SERVICE
I hereby certiff that on the 5th day of May, 2017 ,I caused to be served true and correct copies of
the foregoing document upon:
Original and 9 copies to:
Dianc M. Hanian
Commission Secr€tary
Idaho Public Utilities Commission
472W. Washington
Boisc,lD 83702
Donovan E. Walker'Iirn'taturn
Idaho Power Cornpany
PCI Box 70
Boise. lD S370?
Daphne lluang
Camille Christcn
Deputy Attomey$ General
Idaho Public Utilitie$ Commission
+72 W. Washington (8370?)
PO llox 83720
Boise, lD 83720
Peter J. Richardson
Richardson Adama PLLC
515 N. 27e St.
P0 Box 7218
Boise. ID 8370?
Kiki Leslie A.'Iedwell
l0S Lgt'er Buck Raad
[{uiley, lD 83333
U.S. Mail, Postage Prepaid
Ovemight Courier
Hand Delivered
Via Facsimile
E-mail
diane.hanian@ouc. idaho. gov
x
_T
::r
X
U.S" htfnil, Postage Prcpaid
0vernight Courier
llaml Eelivrred
Via Sacsimile
f;-mail
d,rv*lltsri? i d&h{}p$weI.com
dncketsGid+holrpls+r. qom
t!atunri{tidahoFrwer. cq}m
U.S. MaiI, Postage Prepaid
Ovemight Courier
l{and Delivered
Vitl Facsirnile
li-mail
d+ghCe. hga$qii{ipuc. i daho. s.uS
q-itlxills.qhnst n!?puc. idaho. gov
U.S" Msil, Postage Prepaid
tlvernight Courier
llard Delivered
Via Facsimile
E-mail
pc tqUarln S hartlson adarns. r:om
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Vi* F*csimile
E-mniI lctin+qt$tcax.net
"________?r-
fi,
HECKLER, Df 33
IDAHO SIERRA CLUB
Eenjarnin J. Otto
Idaho Conservation League
710 N. $ixth Street
Boise,ID 8370?
Laura Midgley
231 Valley Club Drive
Hailey,ID 83333
Matthew A. Johnson
\Ym. F" Gigray
White Petenon Sipay & Niehok, PA
5700 E. Franklin Rd", Suirc 300N*p* ID 83687
U.S. Mail, Postage Prrpaid
Overnight Courier
Hand Delivercd
Via Facsimile_-'-'T.A E-msil
botto@, i{fl,lrQ$Iilr "servatir: n. ors
-r
ti.$. Mail, Postage Prcpaid
Overnight Courier
Hand Delivrred
Vis F*csimilc
E-nrail midgleyl? I 5,Bernail.cam
ComCox, LLC
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.0" Box 2900
Boise, ldaho 83701
*-\r-
U.S. Mail, Postage Prepaid
Overnight Courier
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E-meil
m ip.hnsen ag}\ryhi tepqterso n "
com
_Hand tleliveredX U.S. Mail
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_FAXX Email tqm,arkoaqh@aftqoqh,c0m
UIH+ &*r
,IJ
N
Kelsey Jae Nunez
Attorneyfor ldaho Sierra Club
HECKLER, DI 34
IDAHO SIERRA CLUB
BEFORE THE
IDAIIO PUBLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAIIO SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 301
REQUEST FOR PRODUCTION NO. 37: ln Request No. 2(C), ldaho Power was
asked to provide a complete list of "experienced sustained outage line events" for the
line referred to, which line was identified as "as a single-source radial line" that currently
serves the North Valley. The response identifies, inter alia, a 700-minute outage on
1212412009. The response to Request No. 13 provides a list of "all recorded outages on
the Wood River-Ketchum 138kV line 433 from 1995 to present". The referenced list
does not include the 700-minute outage that was included in response to Request No. 2
(C). Please reconcile this apparent discrepancy.
RESPONSE TO REQUEST R PRODUCTION NO. 37:The 700-minute
outage on December 24,2009, was a sustained outage of the line due to the loss of
electric supply when both transmission lines serving the Wood River substation were
out of service due to inclement weather. This 700-minute outage was inadvertently not
listed in the Company's response to Kiki Leslie A. Tidwell's Request for'Production
No.13.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL.3
BEFORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAHO SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 302
RF9UFSf, NO."g: The Company's Application, at 16, states that the expected
duration of sustained outages will be more than 209 minutes per year with the current
transmission configuration. Please provide information on sustained outages occurring
over the previous 36 months including duration, likely cause, and number of customers
affected.
RESPOIISE TO RFA9EST NO. 8: The following table provides the requested
outage information.
Date
Duration
lminuteel
Customerc
Affected Likelv Cause
614/2OL4 46 20,228 Equipment Failure - Broken Cross-Arms
8112/2014 126 9,016 Lightning
LOlL3lzots 465 7,73L Maintenance - Repair Woodpecker Damage
The response to this Request is sponsored by Dave Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.15
BEEORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDATIO SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 303
REQUEqJ FOB PRODUCTI9N-NOI 18: ln Order No. 261A7, granting ldaho
Power's Application to amend Certificate No. 272 to delete the Commission's prior
authorization to construct the second transmission line, the Commission stated at pages
1and2:
Regarding reliability, ldaho Power reports that it has
thoroughly reviewed the reliability of its electric service to the
Ketchum/Sun Valley area. The Wood River/Ketchum 138 kV
transmission line, the Company contends, has had an
excellent record of reliability since its construction in 1962
(only two unplanned outages in the past 14 years, for a tota!
duration of only three minutes). Nonetheless, the Company
states that it has taken a number of steps to further improve
the reliability of the line, including the following: structural
assessment, electrical assessment, fire protection,
avalanche study, conductor assessment, maintenance plan
and emergency action plan.
Please provide the following, include work papers, back up documentation, memoranda
and all other material related to the preparation of each:
(A) a copy of the thorough review of the reliability of the Company's electric
service to the Ketchum/Sun Valley area referred to by the Commission in the above
passage;
(B)
(c)
D)
(E)
(F)
(G)
(H)
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 24
a copy of the structural assessment;
a copy of the electrical assessment;
a copy of the fire protection plan/assessmenUreview;
a copy of the avalanche study;
a copy of the conductor assessment;
a copy of the maintenance plan; and
a copy of the emergency action plan.
RF$F-9ilfSE."TQ REauESr FOR PROpUCTlaN NO. lQ:
(A) No single document encompasses a "thorough review" as described.
Aftachments 1-8 provided on the enclosed CD, when taken together, would comprise a
"thorough review."
(B) Please see the structural assessment and appendices provided as
Attachments 1 and 3 on the enclosed CD.
(C) Please see the electrical assessment provided as Attachment 2 on the
enclosed CD.
(D) A fire assessment was never done. Instead, Idaho Power chose to treat
all the wood poles on the existing WDRI-KCHM Line 433 with a spray-on product called
Fire-Guard from Osmose to protect the poles from wild land fires.
(E) Please see the avalanche study and avalanche maps attached as
Attachments 4 and 5 on the enclosed CD. '
(F) A conductor assessment study has not been prep?r"d. -
(G) The "maintenance fl"n" as referenced in this Request for Production no
longer exists. A verbal historical account of the plan indicates that it reflects the current
maintenance plan as described in the Transmission Maintenance and lnspection Plan
(TMIP) provided as Attachment 6 on the enclosed CD.
(H) Please see the emergency action plans provided as Attachments 7 and 8
on the enclosed CD.
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL.25
Addendum To The Final Re,porl
(Electrical Reliability Stu dy)
IDAHO POWER COMPANY
STRUCTURAL RELIABILITY AND
RISK ASSESSMENT
OF THE
WOOD RIVER - KETCHUM 138 KV LI
December 1993
itrEDMt iff:xtNc.
4700 McMurray Avenue
Fort Collins, Colorado 80525
(303) 22s-0457 FAX [phone]
RELIABILITY AND RISK ASSESSMENT
Eltclricrl Rilirbilitv
Idaho Power Company outage records for the Wood River to Ketchum l38kv
Transmission Line were examined for the years 1980 through 1993. Only two outages
were noted for this period. Of these two outages, one event was caused by weather
(heavy snow) and one event by switching operations. No outages during the last 14 years
were the result of lightning, an extraordinary record.
As a comparative study, in an effort to establish a baseline level of electrical reliability,
outage performance data from the Mid-America Interconnected Network (MAIN) and
Mid-Continental Power Pool (MAPP) was obtained. The available MAIN data is for 1986
only and the MAPP data is for 1977 through 1986. A brief summary of the outage rates
(per 100 miles per year) for the I{APP and I{AIN data follows:
MAPPa
Planned Outage Rate 3.80
Forced Outage Rate 3.1 ITotal 6.91o MAIN
Planned Outage Rate 4.74
Forced OutageRate 1.42Total 6.16
The Wood River to Ketchum l38kv Transmission Line was also analyzed using EPRI
MULTIFLASH software to estimate lightning performance. Table I illustrates the results
of this analysis for a tangent H-frame structure, with unbonded crossarms, using 65'poles,
the predominant structure type and pole height. The actual results are included in the
appendix.
Table I
PREDICTED LIGHTNING OUTAGE RATE
(Flashovers per 100 miles per year)
Notes: (l) See Table 2 for measured resistivity.
(2) Backflashes occur across insulator strings and along crossarrns to pole grounds.
(3) Thunderstorm days per year.
a{
FOOTING
RESISTANCE (I)
UNBONDED CROSSARM (2)
KERAUNIC LEVEL (3)
Resistance Percentage l0 l5 20
25 Ohms l5
2.16 3.2 4.24
50 Ohms 40
100 Ohms 35
200 Ohms 5
400 Ohms 5
i
i
I
The following observations can be made by comparing the actual line outage performance
to the MAPP and MAIN data, and the predicted lightning outage rates:
The actual lightning rates are much lower than the
predicted values.
The geography of this particular line may account for
the absence of lightning related outages.
The unbonded crossarm increases the insulating value
of the structure limiting the incidence of flashover.
The footing resistances used in the lightning outage performance analysis are from the
measured resistiviry values in Table 2 and Figure l. These values illustrate a considerable
range of resistances for the soil types encountered along the line.
Conclusion
The outage records speak for themselves. Two outages in the past fourteen years for a
total duration of three minutes include one weather related outage, attributed to heavy
snow, and one switching outige. The low incidence of lightning in this area combined with
the line's proxiniily to the mountains and relatively good condition of the entire power line
give the Wood Nver to Ketchum l38kv Transmission Line an operating record that is
practically unsurpassable.
a
a
PEI-HLY 22474 (12128193) 24E158{l-22{l{l lrh
BEFORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAIIO SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 304
REQUEST FOR PRODUCTION NO. 13: At page 4 of the Application the
Company asserts that, "This line's access limitations may result in extended outages
. caused by, among other things, vandalism, inclement weather, wood decay,
woodpecker damage, avalanche, fire and micro-burst wind events." Please provide the
duration, cost of response/repair and the date of each extended outage on this line
caused by:
(a) vandalism
(b) inclement weather
(c) wood decay
(d) woodpecker damage
(e) avalanche
(0 fire
(g) micro-burst wind events
Please explain in detail, including itemized costs, and provide copies of all studies and
documentation all of the measures the Company has taken to anticipate and prevent
the above listed causes of outages on the identified line.
RE$PONSE fO REQUEST EOR PRODU-CTION NO. 13: The following table
(Attachment 1) lists for a through g all recorded outages on the Wood River-Ketchum
138 kV Line 433 from 1995 to present.
Duratlon_
off Caus€
5/31/1995 3:02:00 PM 4:45:O0 PM 104 Sustained Maintenance
,6/174997-s:53:00 PM 5:53:00 PM 0 Weather
7 6:40:00 PM PM 4 Weather
3:08:00 PM 3:13:00 PM Unknown
LlU20U 5:44:00 PM 5:54:OO PM 10 Sustained Weather
$/t].t2OO412:04:00 AM tOlLUz0e.4 AM Vandalism
2/l8l2OOS 5:58:00 PM
el?il?aL712:04:oo AM
PM 58 Sustained Equfpfient Failure
349 Sustained Maintenance5:53:OO AM
7 4:28r00 PM PM
PM 7:41:00 PM
11:00:00 PM 6:45:0O AM
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL. 18
o Failure
126 Sustained Weather
4SSSustained Maintenance
Comments
12,3_1oj!? str. &.Xarm Repgir
27439191 Woodoecker Reoair
Provided as Attachments 2 and 3 on the enclosed CD are the summaries of
costs for the two identified work orders, 27340452 and 27439191, respectively.
The response to this Request is sponsored by Tris Yerrington, Transmission
Design Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 19
BEFORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDATIO STERRJA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 305
REQUEST FOR PRODUCTIOIII NO. q: The table below lists some outages
experienced on the existing WDRI-KCHM 138kV line (data taken from ldaho Power's
response to Tidwell's Request for Production No. 13). Please provide the load being
served from the Ketchum and Elkhom substations immediately preceding each outage.
Date Duration Cause
5/31/95 104 Maintenance
8t14t98 5 Unknown
1t1t04 10 Weather
10t11t04 108 Maintenance - Vandalism
2t18t05 58 Equipment Failure
91271',11 342 Maintenance
8t12t14 126 Lightning
10t13115 465 Maintenance - Woodpecker
Load data for the first
two outages is unavailable because the Company only maintains data back to 2000.
Please refer to the table below for the load data immediately preceding each outage.
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB. 11
Date Duration Cause Ketchum Load Elkhorn Load
5/31/95 104 Maintenance Unavailable Unavailable
8114t98 5 Unknown Unavailable Unavailable
1t1to4 10 Weather 33.1 MW 7.4 MW
10t11to4 108 Maintenance - Vandalism 10.8 MW 3.1 MW
2t18tos 58 Equipment Failure 28.5 MW 6.7 MW
9t27111 342 Maintenance 9.5 MW 2.0 MW
8t12t14 126 Lightning 16.3 MW 5.3 MW
10t13115 465 Maintenance - Woodpecker 10.6 MW 4.0 MW
BEEORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
CASE NO. IPC-E-I6_28
IDATIO SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 306
REQUEST FOR PRODUCTION NO. 2: The Application states that
reconstruction of the existing line wil! involve replacing the existing wood structures with
steel structures in approximately the same locations. Application al 17. Could replacing
the existing wood structures with steel structures provide greater resiliency to outages
caused by avalanche, ice loads, fire or micro-burst winds? Please explain.
RESPONS-LI9.BEIIIIEST FOR FROQUCTION NO. 2: Simply replacing the
existing wood structures with steel structures does not ensure they will have a higher
structural capacity. There are steel poles available that have lower strength than some
wood poles that are common and readily available. The existing wood poles'structural
capacity has degraded over time as they have aged. The existing wood structures on
the Wood River-Ketchum line do not have the same capacity they had at the time the
line was built in 1962. The National Electric Safety Code ('NESC") allows for and takes
into account this wood degradation in establishment of its strength criteria. lf the
existing conductor is replaced during the reconstruction, the new structures would need
to have a higher strength capacity in order to meet the NESC requirements generated
by the larger and heavier conductor. lf the existing conductor is not replaced, it is
possible and likely that the proposed steel structures would still have a higher structura!
capacity than the existing wood structures. Additionally, ldaho Power would take into
account known threats to the line, such as conductor icing and avalanche, during the
design process of the reconstruction. This would further increase the structural capacity
of some of the new structures beyond those of the existing line.
Steel structures would eliminate the threat of two of the hazards experienced by
the existing line. Those two threats are structure damage from wildfire and
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 4
woodpeckers. Neither of these threats would affect the new steel replacement
structures. The new steel replacement structures could be designed to mitigate the
threat from weather events such as avalanche, micro-burst wind, and ice loading but
these threats cannot be eliminated. ln particular, because of the extreme nature and
unpredictability of avalanches, it is impossible to design structures that are entirely
avalanche resistant. Threat from micro-burst winds and extreme icing events can also
be mitigated but not completely eliminated. ldaho Power engineering will use its
experience and knowledge to minimize the threats to the reconstructed line to the extent
practical. The reconstructed line would be more resilient to the threats outlined above,
but there would still be significant risk without a second transmission source to the
Ketchum substation.
The response to this Request is sponsored by Ryan Adelman, Transmission and
Distribution Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 5
BEFORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
CASE NO. rPC-E-16-28
IDAI{O SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 307
REQUEST FOR PRODUCTION NO. 51: Please explain the apparent
inconsistency of sourcing redundant transmission lines from a single common
substation. Please also explain the apparent inconsistency of siting redundant
transmission lines along a parallel path from the Wood River Substation to just north of
the golf club. Please explain and document the added reliability the use of a common
substation and parallel paths (from the WRS to the golf club) provides the North Valley.
RESPONSE TO REQUEST FOR PRODUCTION NO. 51: The industry-expected
outage frequency for a transmission substation can range from once in eight to once in
15 years, depending on the configuration. The industry-expected outage frequency for
a 138 kilovolt ("kV') transmission line is once in two years. The construction of a
redundant transmission line changes the outage frequency to once in 3000 years.
ldaho Power has proposed the new transmission line in a separate corridor and
reconfigured the existing transmission line route to avoid one line crossing the other.
This proposal maintains separation between the two lines for alt but a short section.
The short section within a common corridor increases the expected outage frequency;
however, it is expected to occur less frequently than a substation outage. Table 1
contains the outage frequency expressed in Mean Time Between Failures as computed
by the General Reliability SUBREL computer program.
Table 1. Substation and Transmission Line Outage Frequencies
Configuration 4 Breakers -
Sinqle Bus
4 Breakers -
Rinq Bus
Single
Line
Two
Lines
Mean Time Between
Failures (years)7.9 15.4 2.3 3003
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL. 19
BEFORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAIIO SIERRA CLT'B
lr
HECKLER, DI
TESTIMONY
EXHIBIT NO. 308
ln addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 13: Please provide cost estimates for the Company's proposed line
route across Dollar Mountain as described on page 19 of the Company's Application. Please
include electronic workpapers with all formulas and links intacl
REQUEST NO. Id: On page 19 of its Application, the Company explains that the
overhead transmission line route through the Ketchum Downtown District would depend upon
the condemnation of private property. Please provide the Company's estimates of condemnation
costs of the Overhead Transmission line route through the Ketchum Downtown District.
RSQUEST NO. 15: On page 19 of its Application, the Company explains that the line
route across Dollar Mountain may require condemnation of private property. Please provide the
Company's estimates of condemnation costs for the line route across Dollar Mountain.
REQI.JEST NO. 16l In case no. IPC-E-95-6, the Company requested that the
Commission amend CPCN No. 272 to delete its authorization to construct a nEw 138 kV
transmission line from the Wood River substation to the Ketchum substation. In its Application,
the Company stated that it had conducted an extensive reassessment of the feasibility and need
for an additional 138 kV transrnissionn and had concluded that a redundant tine was not
necessary. The Company stated that its reassessment included structural, electrical, fire
protection, and avalanche considerations. The Company also stated that its actual 1994-1995
winter peak load was 55.5 MW, and that this was well below the system's summer capacity lirnit.
For the five year period from 2012 through 2016, system peak has averaged 57.9 MW, ar a4.3Yo
increase over the 1994-1995 winter peak load. Please answer the following questions:
a) What new inforrnation has caused the Company to determine that a redundant 138 kV
transmission line is now needed?
b) Please provide the results of any structural, electrical, fire protection, and avalanche
risks assessments that the Company has used to determine the need for a redundant
line.
sEcoND PRODUCTTON REQUEST
TO IDAHO POWER COMPANY 2 APRIL 3,2Afi
BEFORE THE
IDATIO PT'BLIC UTILITIES
COMMISSION
CASE NO. rPC-E-16-28
IDATIO SIERRA CLTIB
HECKLER, DI
TESTIMONY
EXHIBIT NO. 309
REQUEST FOR PROqUCTION NO. Z: The Company's Application at page 4
states that the North Valley peak demand reached 63 megawatts in 2007. Please
provide documentation of the referenced peak demand. Also for the time of the North
Valley peak demand in 2007 please separately identify the peak demand at the
Ketchum Substation and the Sun Valley Substation. Please, for each year from 1973
fonrvard, identify the North Valley peak demand and the peak demand for the Ketchum
Substation and the Sun Valley Substation at the time of the North Valley peak demand
for each year. Please also identify the peak demand and time of the peak demand for
the Ketchum substation and the Sun Valley substation for each year since 1973.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The peak coincident
demand for the North Valley is the sum of the Elkhorn and Ketchum substation
transformer coincident demands as acquired by the substations supervisory control and
data acquisition (SCADA) system, which are stored in a OSlsoft Process lnformation
("P1") data historian. The Pl historian maintains data back to 2000. Please refer to
Table 7.1 below for the date and time of the coincident North Valley peak demand and
Table 7.2 below for the peak demand of each substation.
Table 7.1
Coincident Peak of North Valley
Year North Vallev Peak (MWl EKHN (MWI KCHM (MW)Date and Time
Winter 00-01 52.5 9.1 43.4 1/l6lffi 8:30 AM
Winter 0'l-02 51.2 8.7 42.5 1?j12101 8:25 AM
Winter 02-03 54.9 9.6 45.3 12124102 9:05 AM
Winter 03-04 54.9 9.4 45.5 12128103 5:45 PM
Winter 04-05 56.3 11.2 45.1 12123144 9:20 AM
Winter 05-06 55.9 12.2 43.7 1il8105 8:50 AM
Winter 06-07 60.6 12.8 47.8 1l13ll7 9:20 AM
Winter 07-08 63.8 14.3 49.5 12131107 6:45 PM
Winter 08-09 59.2 12.9 46.3 1212410810:00 AM
Winter 09-10 57.9 11.9 46.0 1213110910:30 AM
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL. 11
Winter 10-11 62.4 12.9 49.1 12131110 9:50
Table 7.2
Non-Coincident Peaks For Ketchum and Elkhorn Substations
Year KCHM Peak (MW)Date and Time EKHN Peak (MW)Date and Time
Winter 00-01 43.5 11161018:35 AM 9.7 12128100 6:15 PM
Winter 01{2 42.5 12l12li'l8:30 AM 9.9 '121291017:00 PM
Winter 02-03 45.4 12124102 9:00 AM 9.6 12124102 9:00 AM
Winter 03-04 46.1 12128103'10:15 AM 9.8 12128103 6:55 PM
Winter 04-05 45.1 12123104 9:25 AM 12.0 12123104 7:00 PM
Winter 05-06 46.1 12118105 9:25 AM 12.2 1218105 8:55 AM
Winter 06-07 47.8 1113107 9:20 AM 13.3 1115107 9:00 AM
Winter 07-08 50.4 12127107 9:35 AM 14.3 12131107 6:55 PM
Winter 08-09 46.3 12124108 9:40 AM 13.3 12l27lOA 6:55 PM
Winter 09-10 46.0 1213110910:30 AM 14,2 12125109 5:00 PM
Winter 10-11 49.2 1A3111010:05 AM 14.3 1A31l1O 6:55 PM
Winter 11-12 44.6 12123111 9:25 AM 't2.3 121311116:30 PM
Winter 12-13 46.2 1114113 8:55 AM 13.5 12131112 6:15 PM
Winter 13-14 42.7 12129113 9:20 AM 11.7 12129113 6:30 PM
Winter 14-15 46.9 12131114 9:45 AM 13.7 12131114 6:20 PM
Wnter 15-16 46.8 't2131115 6:05 PM 14.3 12131115 6:25 PM
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL. 12
Winter 11-12 55.5 10.8 44.6 12123111 9:25 AM
Winter 12-13 59.5 13.3 46.2 1114113 8:55 AM
Winter 13-14 54.0 11.3 42.7 12129113 9:30 AM
Winter 14-15 59.7 13.7 46.0 12131114 6:20 PM
Winter 15-16 60.8 14.1 46.7 12131115 6:10 PM
BEFORE THE
IDATIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAHO STERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 310
REQUEST FOR PRODUqTION NO: 18: !n its Request For Production No. 16,
Commission Staff references that the Company stated its actual 1994-95 winter peak
load was 55.5 MW. ln response to Tidwell's Request for Production No. 7, the
Gompany provided winter peak load information in Table 7.1, noting that the data
source (Pl historian) maintains data back to 2000. lf it is possible, please provide, in a
format similar to Table 7.1, the winter Coincident Peak for the North Valley during the
winters from 1994-95 through 1999-00, including as many of the following data sets as
are available: the total North Valley Peak (MW), the EKHN (MyV) and KCHM (MW)
substation loads at the time of the peak, and the date and time the peak was
experienced.
Even if the data from the 1990s is limited in availability, please provide the full
Table 7.1 list of data for the Winter 2Arc-17.
: The Company does
not maintain coincident peak data before the year 2000. Please refer to Table 18.1
below for the date and time of the coincident North Valley peak demand for Winter
2016-17.
Table 18.1
Coincident Peak of North Valley
Year North Valley Peak (MW)EKHN (MWI KCHM (MWI Date and Time
\Mnter 2016-17 55.8 11.9 43.9 12131115 6:10 PM
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 23
BEFORE THE
IDATIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDATIO SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 311
t BUrl
City of Ketchum
Planning & Building
March L0,2015
Mayor Jonas and City Councilors
City of Ketchum
Ketchum, ldaho
Mayor Jonas and City Councilors:
Resolution No. 15-012, Regarding Establishment of Energy Conservation Goals for the City of Ketchum
lntroduction/Historv
Since 2007, the City of Ketchum has been working towards achieving a reduction in energy used by the
municipal government as well as the community as a whole. ln 2007, the City of Ketchum City Council
approved a climate protection resolution and general guidelines to address municipal energy costs and carbon
emissions (i.e. greenhouse gas emissions). ln addition, the City committed to reduce municipal emissions by
joining the Cities for Climate Protection Campaign (CCP), a program of the lnternational Council for Local
Environmental lnitiatives (|CLEl). The City also participated in a county-wide carbon emissions analysis by
ICLEI.
Since then, the City has enacted a green building code in 2011 and the 2009 and, subsequently, the 2012
lnternational Energy Conservation Codes. These have served to reduc€ energy consumption in new
construction and additions. ln 2010, the City also undertook a lighting retrofit of City buildings with a grant
from ldaho Power.
With the creation of the Ketchum Energy Advisory Committee (KEAC) in February 2014, the City began to look
at more ambitious ways to reduce energy consumption and support the use of renewable energy technologies.
One project resulting from KEAC's endeavors is the soon to be installed photovoltaic system destined for the
Ore Wagon Museum roof. ln addition, KEAC and the City have received a 2Ot4 National Renewable Energy Lab
grant to learn more about barriers and solutions to solar energy installation and a Rocky Mountain lnstitute
(RMl) award to attend the RMI E-Lab Accelerator workshop in Sundance Utah in late March 2015.
Current Report
As part of the City's commitment to reduce energy consumption and increase use of renewable energy
technologies, KEAC has produced a list of energy conservation goals (Exhibit A of the attached Resolution No.
1s-0L2.).
Financial Requirement/lmpact
While undertaking some energy conservation and renewable energy installation measures may have an
upfront costs, those costs will be recouped in reduced energy use fees over time. Conservation measures tend
to have the most immediate rate of return (often on the order of just a few years), while the cost of
installation of renewable energy systems may take much longer to recoup. However, the environmental cost
of our energy consumption and use of carbon fuels should be taken into account alongside the monetary
costs.
Recommendation
Staff respectfully recommends that the City Council approve the attached resolution establishing energy
conservation goals for the City of Ketchum.
,fu*
Recommended Motion
"l move to approve Resolution No. 15-012, establishing Ketchum's energy conservation goals."
Sincerely,
Rebecca Bundy
Senior Planner / Building and Development Manager
ATTACHMENTS:
A. Resolution L5-0L2, A Resolution of the City of Ketchum, ldaho, Establishing Energy Conservation Goals
for the City of Ketchum, ldaho
Attachment A:
Resolution 15-012:
A Resolution of the City of Ketchum, ldaho, Establishing Energy Conseruation Goals for the CiU of
Ketchum,ldaho
RESOLUTION NUMBER T5-OL2
A RESOLUTION OF THE CITY OF KETCHUM, IDAHO, ESTABLISHING ENERGY CONERVATION GOALS FOR
THE CIW OF KETCHUM, IDAHO.
BE IT RESOLVED BY THE MAYOR AND CITY COUNCIL OF THE CITY OF KETCHUM, IDAHO
WHEREAS, the City of Ketchum recognizes the environmental and monetary costs of continued
overconsumption of energy, including fossil fuels, and seeks to increase its energy resiliency and security;
WHEREAS, there are risks to reliable energy sources for Ketchum due to fires, earthquakes, snow
slides, storms, sabotage and accidents;
WHEREAS, there are risks to the Ketchum economy resulting from increased power, and natural gas
prices;
WHEREAS, the Wood River Valley spends up to S80 million on gas and electricity annually which is now
supporting companies outside the region and the State of ldaho;
WHEREAS, ldaho Power Company is promoting polices and actions that undermine renewable energy
projects thus creating a greater reliance on fossil fuel energy;
WHEREAS, the current energy utilization and systems to support consumption, is contributing to
climate change impacts such as wildfires, drought, unpredictable weather, and water shortages;
WHEREAS, the City of Ketchum has striven to be a leader in energy conservation practices and to that
end has appointed the Ketchum Energy Advisory Committee (KEAC) to research and advise on energy
conservation and renewable energy opportunities; and
WHEREAS, KEAC has made energy conservation goals, as described in Exhibit A, to help guide the City
towards energy resiliency and security;
NOW THEREFORE, be it resolved by the City Council and Mayor of the City of Ketchum, ldaho, as
follows
The City of Ketchum shall adopt energy efficiency goals as outlined in attached Exhibit A: City of
Ketchum Energy Conservation Goals, March 2015.
This resolution shall be in full force and effect after its passage, approval, and publication according to
law.
PASSED by the Ketchum City Council and APPROVED by the Mayor this _day of 2015
Nina Jonas
Mayor
ATTEST
SANDRA CADY
Ketchum City Clerk
Exhibit A:
City of Ketchum Energy Conservation Goals,
March 2015
Overall Energy Conservation Stretch Goals by 2030:. Achieve a 50% per Capita Reduction in Energy Use within the Ketchum community
o Green Building Codes
o Education
o lncentives
o Smart Systems. Achieve a 75% Reduction of Energy Use within City Operations
o Retrofit Lighting and Mechanical Equipment
o New Buildings to be Net Zero Energy
o Conservation Education. Achieve 100% Renewable Energy Use for City Operations
o Buying Renewable Energy Offsets
o lnstallation of Renewable Energy Systems
o Local Power Generation. Achieve 50% Local Renewable Energy Generation for Ketchum Community
o Solar Farm
o Roof Top Solar
o Micro-grid
o Wind Farmo Achieve 100% Green House Gas Reduction for City Operations while Maintaining High Level of
, Customer Service
o Energy Generation
o Alternative Mobility
o Buildings LEED Gold Equivalent
o Operational Change lncentivesr Achieve 75%Green House Gas Reduction within Ketchum community
o lncrease Bike/Pedestrian Activity - Measured by vehicle miles traveled, Blaine County
Recreation District (BCRD) usage numbers
o lncrease Transit Ridership - measured by Mountain Rides numbers
o Create a More Walkable Community
o see Energy Reduction Goals
o Work with School District to lncrease Student Ridership
Assumptions
Goal year: 2030
Baseline data:
o ICLEI data from 2007:
o City of Ketchum, Climate Protection Campaign, Carbon Emissions Baseline lnventory,
M unicipa I Analysis, 2004, 2007
o Blaine County Community Carbon Emissions Data, 2007
o Other as obtained from ldaho Power, lntermountain Gas, propane distributers, Mountain
Rides, BCRD, greenhouse gas calculation websites, etc.
Area lWho: City of Ketchum Operations and Ketchum Community (manage what we have control
over)
Definitions:o Energy = electricity, natural gas, propane, wood
. Renewable = solar, wind, geothermal, biomass, hydrogen
. Local = 100 mile radius
BEFORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAIIO ,.SIERRJA, CLT'B -IJ
HECKLER, DI
TESTIMONY
EXHIBIT NO. 3L2
REqUEST FOR PBODUCTION NO. 13: ln Figure 2 ol Appendix C of the
Northem Wood River Valley - Local Backup Electical Supply Repod (lhe City of
Ketchum Solar Generation Assessmenf), the Company shows the City of Ketchum load
on December 23,2014. Please provide a figure, in similar format, showing both City of
Ketchum load and total Ketchum substation load for that same day.
The figure below
shows the total load at the Ketchum substation and the total load in the City of Ketchum
on December23,2014.
l2l23l201.4 City of Ketchum toad vs Ketchum Substation Load
t5
30
2t
3
=
20
15
0
t0
t?l455re9 10 1l r2 lt t4 15 15 1' lE 19 20 21 22 23 2a
Hour
lKctehumSubstrtlon rCltyofKctchum
The response to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 16
BEFORE THE
IDAHO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAHO SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 313
5t4t2011
News
TnE SpoxEsMAN-REvrErv
Sports A&E Obits
ldaho
Knowledge gained as power conserved I The Spokesman-Review
+
Menu E
Wash Business
BUSINESS
Knowledge gained as power
conserved
Sun., April 9,2017,7:17 a.m.
By Elaine Williams
Lewiston Tribune
Ivgo
A volunteer group of Pullman Avista customers saw their power consumption
decline by g.g percent after they were given high-tech thermostats.
The devices were distributed as part of a smart grid project where Avista
deployed a number of cutting-edge technologies and gathered data to see if their
performance merited putting them into broader use.
Overall, the upgrades are saving 43,ooo megawatt hours per year in Pullman
and Spokane, not counting the conservation by the Pullman thermostat users.
"We exceeded our goal," said Curtis Kirkeby, an engineer at Avista. "We did our
normal utility business case. It met that criteria."
Kirkeby declined to share dollars saved versus those that were spent, but he said
that generally Avista looks at the rate of return on investments over 20 years.
http://www.spokesman.com/storiesl20lT laprl09lknowledge-gained-as-power-conserved/v5
51412017 Knowledge gained as powerconserved I The Spokesman-Review
And in this instance, Avista didn't assign a value to the 2.S million customer
outage minutes that were avoided from August of 2oL2 through September of
2oL6. That was because the benefit came through equipment that had other
advantages, such as reducing consumption.
The research completed by Avista was one part of the Pacific Northwest Smart
Grid Demonstration Project. A federal grant of $rZB million was split among 11
utilities in Idaho, Washington, Montana, Oregon and Wyoming.
Each grant recipient tested emerging technologies to see how well they made
strides in conservation and reliability at a reasonable price. The data was
documented and shared nationally.
Elements of the smart grid that Avista introduced have been put into broader
use and as the utility moves forward, it will consider what it learned anytime it
makes a major decision about infrastructure, Kirkeby said.
In the case of the thermostats which are connected to wireless internet, Avista is
encouraging residential customers anywhere in its Idaho and Washington
territory to buy them by offering rebates of as much as $roo. The retail price
runs anywhere from $roo to $goo and installation costs vary.
The thermostats allowed 75 Pullman families during the project to adjust the
temperatures in their homes using smartphones, which could be done even if
they weren't on the premises.
They also provided information about darly usage patterns and enabled users to
see what their estimated monthly bill would be at any time.
Almost as surprising was what happened when Avista activated another feature
of the thermostats, one that allowed the utility to adjust the temperature in
private residences up or down by two degrees on days where extreme hot or cold
taxed the utility's power resources.
hnp://www.spokesman.com/storiesl20lT laprlO9lknowledge-gained-as-1rcwer-conserved/2t5
5l4l2ll7 Knowledge gained as power conserved I The Spokesman-Review
Avista had high acceptance from the participants - who had the option of
rejecting the thermostat changes - but the utility found other smart grid
measures showed more promise.
One is invisible to customers. Voltage in wall outlets was diminished by two
volts, something that was possible because the improvements Avista made
ensured a constant flow of power in the lower range without diminishing the
performance of appliances like toasters. That technology also helped prevent
outages.
Another strategy that succeeded involved closer cooperation with Washington
State University. Avista now has a protocol where it can request power from the
school's generating facilities, which are powered with natural gas and diesel.
It can also have the school reduce its demand through minor changes in how it
operates its heating and cooling system for classrooms, conference rooms,
offices and hallways, but not more sensitive areas such as laboratories or
dormitories.
Even though the smart grid project is technically over, Avista continues to
examine innovations, Kirkeby said.
"Everything is on a road map where we have customers gain value from what we
do and participate in what we do."
PUBLISHED: APRIL 9,2017,7:17 A.M.
Tags: Avista, electricity, energy, Pullman, smart grid, thermostats
Click here to comment on this story >>
http:/i www.spokesman.com/storiesl2OlT laprl09lknowledge-gained-as-power-conserved/315
BEFORE THE
IDATIO PT'BLIC UTILITIES
COMMISSION
CASE NO. IPC-E-I6-28
IDAIIO SIERRA CLT'B,
HECKLER, DI
TESTIMONY
EXHIBIT NO. 3L4
REQUEST FOR PRODUCTION NO. 1: The Application states that the existing
138 kV radial transmission line in the North Valley will require reconstruction and that
such reconstruction "is required whether or not a redundant transmission line is
constructed." Application at 16. Please provide the Company's estimate for the costs
of reconstructing the existing line, as well as the Company's plan for recovering those
costs.
RESPONSE Tq, REOUEST FOR PRgBqC.r!!P-!l NO. r: No desisn work has
been performed on the reconstruction of the existing transmission line, nor have any
detailed cost estimates been developed for the reconstruction of the existing Wood
River-Ketchum 138 kilovolt ("kV') transmission line. Also, the degree of reconstruction
for the existing line has not been fully scoped. However, two preliminary cost estimates
have been prepared, assuming the project would require a complete line rebuild
(conductor and structure replacement). Those,two preliminary cost estimates and the
nature of the projects are described in the attached document. ln addition, the
document talks about a third method to accomplish the rebuild by doing the work on an
energized line. This third "hot" method is not estimated and the reasons for this are
explained in the document.
While the Company has not developed a specific plan for recovering costs
associated with reconstruction of the existing line, at this time, it is anticipated that these
costs wil! be recorded to electric plant-in-service in the same manner as other capital
projects for inclusion in a future rate filing. However, if incremental costs are incurred
related to non-standard construction (e.9., building a temporary line to accommodate
line reconstruction due to local opposition to permanent redundant service), the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 2
Company may consider directly assigning these costs to the local jurisdictions
responsible for the incurrence of these costs.
The responEe to this Request is sponsored by David Angell, Transmission and
Distribution Planning Manager, ldaho Power Company, and Tim Tatum, Vice President
of Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSETO THE FIRST
PRODUCTION REQUEST OF IDAHO SIERRA CLUB - 3
FORE THE
CASE NO.; IPC.E.I
IDAHO PUBLIC UTILITIES COMMISSI
Y
RESPON$E TO IDAHO SIERRA CLUB'S
REQUEST FOR PRODUCTION NO. 1
Wood River - Ketchum 138kV Line 433: Rebuild Options for Existing Transmission Line
Three construction scenarios have been identified that would allow the existing Wood River - Ketchum
138kV transmission line to be rebuilt. Preliminary costs of these three options have been developed and
are shown below, along with assumptions that were made for each scenario. The three scenarios are
listed in order of cost, from least to most.
Option 1 - BASE: This option involves the replacement all of the existing wood, H-frame structures on
the existing H-frame line with similar, steel H-frame structures along the current alignment, in
approximately the same locations. The entire 12.6 mile route would be re-conductored with 397.5 ACSR
lbis conductor. This option assumes that the existing line can be taken out of service for long periods (6
months May - October) and that the existing load at Ketchum and Elkhorn substations will be supplied
from a separate source. This separate source is presumed to be either a second 138kV source from
Wood River to Ketchum substation or a 138kV source from Wood River to a new distribution station
located south of the Wood River Medical Center. The estimate for this option assumes the use of
existing right-of-way with no new acquisition necessary. This estimate does not include any new access
road work, landscaping repair or traffic control. lt does include the cost for removal and disposal of
existing structures and conductor.
Estimated Cost: $6.2 million (includes 15% general overhead and 8% AFUDC)
Option 2 - Shoo-fly: This option involves the replacement all of the existing wood, H-frame struct{rree
on the existing H-frame line with similar, steel H-frame structures along the current alignment, in
approximately the same locations. The entire 12.5 mile route would be re-conductored with 397.5 ACSR
lbis conductor. This option assumes that the existing line can be taken out of service for long periods (6
months from May - October) and that the existing load at Ketchum and Elkhorn substations will be
supplied from a temporary shoo-fly line to be built from Wood River Sub to Ketchum Sub along a route
that roughly follows Highway 75. The temporary shoo-fly will only be in place while the existing line is
rebuilt and will be removed after the rebuild is complete. The shoo-fly would consist of single, wood-
pole structures with horizontal post insulators and would have 300 foot typical span lengths. After, the
existing line is rebuilt, the shoo-fly would removed and the majority of materials (poles and insulators)
would be salvaged. The conductor used for the shoo-fly would be scrapped. The estimate for the
rebuild of the existing line assumes the use of existing right-of-way with only a small amount of
temporary ROW acquisition necessary for the shoo-fly. This estimate does not include any new access
road work or landscaping repair. lt does include traffic control for the shoo-fly work. lt does include the
cost for removal and disposal of existing structures and conductor on the existing WDRI-KCHM 138kV
line.
Estimated Cost: S9.4 million (includes L5% general overhead andS% AFUDC)
Option 3 - Hot Work & Outages: This option involves the replacement all of the existing wood, H-frame
structures on the existing H-frame line with similar, steel H-frame structures along the current
alignment, in approximately the same locations. This option assumes that the existing line cannot be
taken out of service for long periods and must remain in service as much as possible to serve the load at
Ketchum and Elkhorn Substations. lt is not feasible to replace the energized conductors without an
extended outage, so the existing 4/0 ACSR conductor on the entire 12.6 mile route would remain in
place and would be transferred to the new structures under this option. Since no long-term line outage
will be available under this option, as much structure replacement work as possible will be done with
the line energized. ln order to replace the H-frame structures with the line energized, unrestricted, level
access to both sides of the structure must be available (approximately 50 feet of clear space on each
side). This clear space is necessary to position large cranes and bucket trucks on each side of the
existing structure to lift, spread and support the existing energized-phase conductors away from the
immediate vicinity of the structure using insulated equipment. lf either or both sides of the structure
are restricted by residential development, vegetation or steep terrain, then the structure could not
safely be replaced using "energized methods" and an outage would be necessary. Each of the
structures was evaluated using aerial photos and topographic maps to determine if adequate access was
available. lt was determined that approximately 34% of the structures (35-40 total) were candidates for
being changed out with the line energized. Approximately 50% of the structures (50-50 total) on the
existing line would require outages to replace the structures and about t6% (20 structures) of the
structures in the vicinity of The Valley Club are a newer vintage and would not need to be replaced. ln
order to replace the 50 to 60 structures that require outages, it is preliminarily estimated that it would
require 20-25 individual 8-hour outages, if two crews were assigned the work. lt follows, that this
number could be reduced to L0 to 13 individual 8-hour outages if four crews were mobilized to work the
outages. Given the large number of customers and businesses that would be adversely affected by this
number of outages, this option would have much larger societal impacts than Option I or 2. Option 3
also has much greater environmental impacts because of the large, level equipment pads that must be
built around the structures that would be replaced "hot". Option 3 also has inherent worker safety
issues that result from working on energized conductors. This increased safety risk is impossible to
quantify. Also, Option 3 does not replace the transmission conductor, so it doesn't resolve all of the
issuesof reliabilityandaginginfrastructurethatarethegoalofthisproject. BecauseOption3comesat
a higher construction, societal, safety and environment cost than either Option t or 2, and because it
produces less long-term benefit, it has been determined that this option is not practical or feasible and
will not be pursued further.
Estimated Cost: Not determined because of difficulty quantifying construction, societal, safety and
environmental costs.
BEFORE THE
IDAIIO PUBLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDATIO SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 315
5t4t2017 Municipal I Generac Industrial Power
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see our orivacv policy.
GIEN EHAG" I rtuous?FrrAt.
EN/ERGENCY POWER FOR
N/UNICIPALITI ES
GENERAC INDUSTRIAL POWER HELPS
MUNICIPALITIES RISE TO THE CHALLENGES OF
SERVING AND PROTECTING COTVN/UNIry N/EIVBERS
lVunicipalities are
continually asked to
do more with less
whether its
maintaining
municipal buildings,
providing a vast
array of community
services, or
providing protection
for citizens during
emergencies. There
is no one "cookie-
cutter" generator
solution that will
meet the incredibly
diverse needs of
municipalities. The
good news is that
Generac lndustrial Power provides a wide range of gensets, accessories, controllers, and enclosures, so
we can help you find the optimum solution to surpass your challenges.
Your Need: Emergency Preparedness
http://www.generac.com/i ndustrial/industrial -solutions/munici pal#results.U6
51412011 Municipal I Generac Industrial Power
ln the wake of recent hurricanes and massive flooding in the south and east, the role of emergency
preparedness has never been greater. Citizens not only depend upon crisis services including first
responders and 91'1 call centers, but they also look to municipalfacilities for shelter during the storm
Authorities may also need municipal buildings to act as command centers in the wake of a disaster.
lf that were not enough, FEMA and other governmental agencies are asking cities and towns to deliver
more robust support systems to community members living in underserved areas and government-
sponsored housing unit.
STANDBY POWER FOR EMERGENCY SERVICES
Police and fire stations, and 911 call centers must function during emergencies. Generac provides diesel
gensets from 50 kW up to 2 MW to meet NEC and NFPA requirements for on-site fuel. And many of
these gensets can be paralleled to meet even greater power requirements. Generac's Modular Power
Systems (MPS)feature on-generator paralleling so our units do not require dedicated and expensive
third-party switchgear.
Future expansion generators simply tie directly to the generator bus. Because the paralleling is already
built into the generator, the Generac MPS system inherently has greater flexibility for groMh, requires
less electrical room space, and reduces initial capital cost, which can help with your always tight
budgets.
Paralleling also works for many government housing units as rooftop installations are being specified so
flooding doesn't impact power supply. MPS gensets are smaller and lighter weight which helps balance
http://www.generac.com/industrial/industrial-solutions/municipal#results.2t6
51412017 Municipal I Generac Industrial Power
the rooftop load, while still providing the needed kWs.
Backup Power for Light Rail Crossings
IVany communities are turning to light rail systems to provide more efficient ways for citizens to access
downtown areas while at the same time helping to reduce emissions and parking challenges. Since light
rail trains typically cross many busy intersections, during an outage, it's vital crossing signals continue to
function to help prevent dangerous accidents.
For light rail crossings, natural gas generators are becoming the preferred choice. tVost light rail systems
are located along the natural gas right of way making it easy to tie into the service lines. Generac offers
gaseous generators from 22 kW up to 500 kW nodes, providing the power needed for most applications
with limited service and maintenance requirements. ln addition, these units can be paralleled to provide
more kWs, as needed.
Our technological advances in natural gas generators have earned us awards from Frost and Sullivan as
"The Natural Gas Generator Company of the Year", ln addition, our 500 kW natural gas generator
recently earned a Silver Award from the readers of Consulting-Specifying Engineer magazine. Any
questions?
PROVIDING CLEAN WATER FOR CITIZENSTHROUGH
WATER AN D WASTEWATER TREATN/ENT FACI LITI ES
The demand for safe water is growing rapidly. And as water consumption doubles globally every 20
years, municipalities are more focused than ever on using this resource wisely and efficiently.
Computers control water-processing and delivery systems, and sophisticated digital water meters and
http://www.generac.com/industrial/industrial-solutions/municipal#results.3t6
5l4l20l7 Municipal I Generac Industrial Power
data analysis can improve operations and reduce costs. Yet those innovations and increasing regulations
have put even more pressure on facilities to have reliable backup power systems.
Both water and wastewater facilities place great demands on pumping equipment for consistent water
distribution and treatment processes. When pumps go offline due to power outages, these processes
are halted and water distribution ceases. ln the case of large municipalities, returning all plant systems to
normal operations and resuming the distribution of water can be a daunting task. During prolonged
outages, under-treatment may occur, and the penalties both in terms of financial and environmental
damage can be severe,
HOW GENERAC RISES TO THE CHALLENGE
Generac lndustrial Power can provide the kWs you need with a variety of fuel sources. We offer
everything from 1 MW of plant backup power up to 100 MW of primary power with our paralleled MPS
for critical pumping stations. Generac lndustrial Power can tailor a robust power system that meets your
specific requirements - delivering dependable power when you need it most.
:iqSEL
CASE0us
*
15 kW 2
KW
d),'"*-.-.,,..-'
sao kw,..nn,,,,o.*;#-.-ft#-'."""-....-''.,,..
2 lltw
And our tough-as-nails diesel gensets can be paralleled with our natural gas and bi-fuel units, providing
the extended runtimes you may need, You can also choose from larger alternators, sound attenuated
enclosures, extreme performance enclosures, a variety of control systems, and different size base tanks
Each one designed to meet your specifications seamlessly.
Generac is the Leader in Municipal Support
Providing a substantive backup power response requires strategic planning including the location of
genset units, fuel choices, sizing requirements, and paralleling potential. We also understand the
complexities involved with RFPs and budget considerations, and we provide a variety to tools such as
http://www.generac.com/industrial/industrial-solutions/municipal#results 4t6
51412017 Municipal I Generac Industrial Power
SpecExpert, to help you create custom specs, and Power Design ProrM for sizing and analysis of
different options, to assist you in this process.
At the same time, we think your best resource is our network of lndustrial Power Distributors, as they
know your local community codes, localAHJs, and they can assist in countless ways. Count on our
distributors to serve and protect you during this process.
We know cities never sleep and at Generac-neither do we.
ADDITIONAL RESOURCES
Case Studies
. On the Road with a N/odular Power Svstem - Providing Standby Power for a Highway Toll Plaza
. Four Times the Power - Toll Bridge and Plaza
. N/PS - The best N + 1 Solution for Wastewater Treatment Facilities
. Emergency Power for Emergencv Services
. lr/ission Critical Public Safety Building Powers Up for Emergencies
. Generac Helps to Keep 'em Flying
. When a Wh6le Town is Depending on You - Providing Standby Power to Stockton East Water
Treatment Plant
White Papers
. lt/edium Voltage On-Site Generation Overview
. Natural Gas Whitepaper
. MPS Whitepaoer
GENERAC INDUSTRIAL POWER'S FLEXIBILITY
FINDA DISTRIBUTOR
http://www.generac.com/industrial/industrial-solutions/municipal#results.5t6
BEFORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAIIO SIERRA CLT'B
HECKLER/ DI
TESTIMONY
EXHIBIT NO. 3L6
5t4t20t7 Emergency Generators Power Town After Sandy Comes Ashore I FEMA.gov
Sea rch Release date: June 21 , 2013
Release Number: 4086-11 4
TRENTON, NJ. - Superstorm Sandy left many thousands of
homes, municipal services and emergency service facilities
across NewJersey wlthout power.
But Seaside Heights, a
Seaside Heights, NJ generators were essential for emergency
services during Superstorm Sandy. - Photo by Rosanna Arias
.Jersey Shore barrier island borough, escaped the massive
power outages that most other areas faced because of its three
peak-demand generators which had been protected from high
water when they were installed.
FHMAo Emergency Generators Power
Town After Sandy Comes
Navigation AShOfe
La nguages
News Releases (/news-
releases)
Fact Sheets (ifact-
sheets)
News Desk
Contacts (/media-
contacts)
https://www.fema.gov/news-releasel20l3l0612llemergency-generators-power-town-afier-sandy-comes-ashore l4
5t4t20t7 Emergency Cenerators Power Town After Sandy Comes Ashore I FEMA.gov
"lnitially, we powered them on to supply electricity for the
firehouse, emergency management, the police headquarters
and the municipal building," Seaside Heights Borough
Superintendent William Rumbolo said.
Because Sandy's impact on the borough would be
unpredictable, officials began preparations for the storm by
having emergency workers and officials go door-to-door
encouraging residents to evacuate. As Sandy got closer, officials
moved the borough's fire trucks inland to Toms River to escape
anticipated flooding and brought in three army trucks the Office
of Emergency [Vanagement Coordinator obtained for
emergency tra nsportation.
When Sandy came ashore, the storm brought winds that
knocked down telephone poles, knocking out power and
trapping emergency responders and residents who failed to
heed the evacuation warnings.
Emergency responders (approximately 45 firemen and 30
policemen) were able to use the generators to keep electricity
going and complete rescue missions.
For three weeks, Seaside Heights used the generators to power
the community. "We fired up the generators and made some
connections so that we could run the whole town," Rumbolo
said. Borough officials originally proposed the idea of obtaining
generators to help reduce the cost of wholesale power during
peak demand times.
The three two-megawatt diesel generators and their installation
cost the borough nearly $4 million, The generators were initially
intended to be used during heavy power use hours, to reduce
community power consumption and give the borough a better
rate when purchasing electricity,
https://www.fema.gov/news-releasel2Ol3lO612l lemergency-generators-power-town-after-sandy-comes-ashore 2t4
514120t7 Emergency Generators Power Town After Sandy Comes Ashore I FEMA.gov
The borough made the decision to power the generators with
diesel fuel in the initial installation, which worked out well during
the storm since natural gas - the other option - was unavailable
to the island after the storm.
"We were able to truck in diesel fuel and run the generators,"
said borough officials. "lf these things had been powered by
natural gas, we would not have been able to use them,"
Sandy brought flooding to the area but the generators had
been installed approximately 43 inches above the ground and
one foot above the Base Flood Elevation.
Although Seaside Heights officials did not buy and install the
generators primarily to be a backup power source, having them
was crucial to keep the town running in the aftermath of the
storm.
Officials powered up two hotels in the borough so that the
responders and those rescued could have a place to stay. They
were also able to power the water main to supply running water
throughout the borough.
Having the generators protected from storm surge and fully
operational gave the borough the ability to safely house the
emergency responders as close to the damaged area as
possible enabling them to continue uninterrupted response
operations.
FEIVA's mission is to support our citizens and first responders
to ensure that as a nation we work together to build, sustain,
and improve our capability to prepare for, protect against,
respond to, recover from, and mitigate all hazards.
Follow FEN/A online at www.fema.eov/bloe (/blos),
u rl =//www.twitte r. co m/fe m a ), www. fa ce b o o k. co m/fe m a
https://www.t'ema.gov/news-releas el20l3l0612l lemergency-generators-power-town-atter-sandy-comes-ashore
?
314
5t4t2011 Emergency Generators Power Town After Sandy Comes Ashore I FEMA.gov
(/sood bve/eood bve. i s o?u rl =//www.fa ce boo k. co m/fe m a ), a n d
u rl=//www.youtu be.com/fe ma). Also, fo I I ow Ad m i n istrato r Cra ig
Fu gate's a ctiviti es at www.twitte r. co m/c ra i satfe m a
The social media links provided are for reference only. FEIVA
does not endorse any non-government websites, companies or
applications.
Last Updated:June 21,2013 - 17'.35
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https://www.fema.gov/news-releasel2Ol3l06l2l lemergency-generators-power-town-after-sandy-comes-ashore 114
BEFORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAIIO SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 3L7
Idnb SosEr Cryruy
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BEFORE THE
IDATIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAIIO SIERRA CLT'B
HECKLER, DI
TESTIMONY
EXHIBIT NO. 318
REQUEST FOR PRODUCTION NO. 19: The Company's Application states at
page 11 that "sun Valley stated that at the regular City Council meeting of September 1,
2016, the council unanimously agreed that the redundant line project was necessary
and vital for its community..." The Mayor of the City of Sun Valley stated at the
referenced meeting that, "lt is not a vote, it is an expression of our wishes as far as how
they will tackle this project that they are mandated to do to provide us with power. Thev
lldaho Povwrl have decidqd-that thev need to do this they are asking us to think about
how we want it done." Please reconcile the Application's assertion that the City of Sun
Valley "agreed that the redundant line project was necessary" with the Mayor's
explanation that the need for the line was already "decided" by ldaho Power and that
the City Councilwas only asked to "think about how we want it done.'l
BESPONSE TO REQUEST FOR PRODUCTION NO. 19: The Company's
statement on page 11 of its Application refers to a letter received from the City of Sun
Valley, dated September 29,2016. which was sent to the Company as well as filed with
the Commission. The letter is an expression of the City's official action, and the words
and contents of the letter speak for themselves.
The letter, signed by Peter M. Hendricks, Mayor of the City of Sun Valley, states
"the City has been thoroughly informed on the purpose and need, as well as the impacts
of potential routing options." The letter continues to state that:
At the regular City Council meeting of September 1't, the
Council unanimously agreed on the following project scope
and components:
1 City of Sun Valley audio transcript, September 1, 2016 at hour 1:45, emphasis provided. See:
h[p:llsullttalley. granicus.comlMediaPlayer. ghp?view_id=3&clin id=772
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF KIKI LESLIE A. TIDWELL - 26
1)That the redundant line proiect is necessary and
vital for our community, which is geographically
isolated, has substantial wildfire risk, relies heavily on
tourism during the winter, and experiences severe
winter weather.
The letter continues:
That the best location at which to underground
the line is near the intercections of Highway 75
and Elkhorn Road, because it offers the best
combination of low project cost and low visual impacts
to the combined communities of Ketchum and Sun
Valley.
(Emphasis in original.)
The Mayor also stated that the "City of Sun Valley understands that this line will
provide the opportunity to eventually replace the aging and dilapidated Wood River-to-
Elkhorn line, which is also important to maintaining the reliability of electrical power in
our community."
The response to this Request is sponsored by Michael J. Youngblood, Manager
of Regulatory Projects, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF K]KI LESLIE A. TIDWELL.2T
2)