20170623Heckler Rebuttal.pdf

Kelsey Jae Nunez, ISB No. 7899
Kelsey Jae Nunez LLC
920 N. Clover Dr.
Boise, ID 83703
208.391. 2967
kelseyG kelseyj aenunez . com
Attorney for ldaho Sjerra Club
BEEORE THE IDAHO PUBLIC UTILITIES COMMISS]ON
IN THE MATTER OF IDAHO POWER
COMPANY' S APPLICATION FOR
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR WOOD RIVER
VALLEY
CASE NO. IPC-E-16-28
IDAHO SIERRA CLUB
REBUTTAL TESTIMONY
OF
MICHAEL HECKLER
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A. Please state your nane and business addrese.
A. Michael Heckler at the Idaho Sierra Club, 503 W.
Franklin Street, Boise, Idaho 83702.
A. Wtrat is your role at the Idaho Sierra Chrb?
A. I am the Chair of the fdaho Sierra Club's Energy
Committee.
O. Are you the sane Michael Heckler that previously
provided direct testimony for the fdaho Sierra Club in thig
matter?
A. Yes.
A. What is the scope and purpoge of, your rebuttal
72 testinony?
A. My rebuttal testimony will provide Idaho Sierra
Club's response and rebuttal to the testimony offered by Michael
Morrison, the witness for the Pub1ic Utilities Commission Staff.
While we agree with a significant portion of Staff's direct
testimonyr l we are concerned about a potential misreading of
1 Eor example, we agree that: (1) there is no compelling case for
redundancy; (2) if the Commissi-on deems a second line necessary,
"cities/counties" should be responsible for footing the cost of
any undergrounding of the Line; (3) the existing line is nearing
the end of its useful life and should be rebuilt; and (4) using a
temporary shoo-f1y line to provide power while re-building the
existing line can facilitate that re-building process.
HECKLER, DI-REB 1
IDAHO SIERRA CLUB
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implj-cations based on that testimony. An example of where a
could come from Staff's conclusion thatmisreading might arise
local generation and storage options exceed the costs of the
Company's
to suggest
resources
the case.
V[hi1e
redundant
proposed transmission line.' Some might read this quote
that an adeguate review of distributed energy
("DERs") has been conducted. We do not believe this is
1-0
DERs may not cost-effectively substitute for a
line, the data in the current record is based upon
unreasonable assumptions related to cost, the need for DERs to
back up entirety of 1oad, and the failure to consider a
combination of resources. Consequently, the record does not a1low
an adequate review of DERs or their applicability i-n other
relevant contexts. We believe that a combination of a rebuilt
line on the existing right-of-way combined with aome amount of
DERs could potentially supply reliable electric service in the
North Wood River Va11ey (*NWRV"). Such a combination of resources
could provide reliabl-e service at a lower cost than the proposed
redundant line. We believe the current record does not contain
adequate information to support a concl-usion that the proposed
redundant line is the "Ieast cost" or even a reasonable cost
22 alternative.
2 Direct Testimony of Michael Morrison at 25.
HECKLER, DI-REB 2
IDAHO SIERRA CLUB
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1 Similarly,
2 a shoo-fly line
3 line, we do not
4 address concerns
while we are supportive of Staff's request that
be used to facilitate rebuilding the existing
think the record contains adequate information to
t.o cost and routing of such a temporary
options that have not been considered
related
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line. Alternative siting
may save money and address local- concerns.
The implications of Staff's analysis show that the
Company's proposal, as it currently stands, is insufficient to
solve the problems associated with this docket. 9ile assert that
the record is missing necessary data and therefore the Commission
cannot determine the least-cost or most cost-effective
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12 alternative unless and until we have additional data. As we
13 proposed in our direct. testimony, a technical review committee
t4 may be effective in collecting the data needed to determj-ne
whether there is a lower cost alternative that has not yet
been considered.
A. Iftrat are some of the pubJ,ic's interests in
addressing these data deficiencies?
A. One of the public constj-tuencies that deserves
resolution of a process they started in 2007 is the Community
Advisory Committee appointed by ldaho Power (the "CAC").
Without additional- data being added to this record, the issues
the CAC worked on cannot be adequately resolved.
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HECKLER, DI_REB 3
IDAHO STERRA CLUB
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The CAC did the best they could within the confines of
the process they were given and the problem they were tasked
to solve. As f noted in my direct testimony, the CAC was not
tasked with analyzing the technical need for a redundant line
or technologically feasible alternatj-ves to redundancy, but
instead focused on siting and l-and use issues for a redundant
line that was presumed necessary from the beginning.
The members of the CAC worked hard for many years to
serve the public interest, and they deserve
efforts. It is not enough to give
simple "thumbs up" or "thumbs down
to which the CAC was dedi-cated will
some resolution
the Company's CPCN
" - the public
be better served
10 for their
11 request a
72 interest
13 by a broader dj-scussion on al-ternatives to redundancy. And
L4 Staff's testimony could be construed to stand in the way of
15 that discussion.
16 o Wtry do you think Staff testi.mony could
11 constrain a broader discussion?
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A. In his direct testimony, Mr. Morrison states,
"The questions before the Commission are: 1) is a second line
needed? 2) If sor what facilities are necessary? 3) What costs
should be borne by the general body of Idaho Power
HECKLER, DI-REB 4
]DAHO SIERRA CLUB
22 ratepayers?"3 We believe a review limited to these questions
3 Morrison Direct at 3
1 is too narrow and that Staff testimony inherently extends
2 beyond these bounds. An appropriate review of alternatives
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implied by Staff's analysis is necessary to resolve the
fundamental- questi-on of what al-ternative makes the most
technical and economic sense to contj.nue to supply reliable
electric service in the NVIRV.
a How rould you rework the framing of those
questions to iryrove the analysis?
A Staff suggested that some investments may be
10 warranted in the NWRV system but concluded that the Company
11 failed to prove that a redundant line was needed. Thus, w€
t2 believe that it is necessary to more thoroughly define what
13 facilities, if dny, are needed jn lieu of a redundant 7ine.
t4 A. Can you give atr exanEiJ.e of rhat might have been
15 different if the analysis had focused on aLternatives ia lieu
16 of the redundant line?
7'l A. Eor instance, Mr. Morrison stated,
18 "Nevertheless, a second line will be necessary to facilitate
19 repair of the existing transmission 1ine."4 We agree that a
20 temporary "shoo-fLy" Ilne is like1y to be an excellent
21, al-ternative for providing service while repai-ring the existing
HECKLER, DI-REB 5
IDAHO SIERRA CLUB
a Morrison Direct at 3
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line.s However, the current record lacks information about
alternatives for routing the temporary line Staff asks the
Commission to direct the Company to build (such as routing the
temporary line to the Elkhorn substation rather than the
Ketchum substation).
This gap 1n j-nformation is especially problematic because
Idaho Power denj-es the value and practlcality of the temporary
includeshoo-fly line due to its perceived faults, which
problems caused by routing through Ketchum. In response to
10 Staff's Request for Production No. L4, which asked about
11 runnj-ng a shoo-fly from Hailey to Ketchum, Mr. Angel1 listed
12 what he considered to be five problems with that option: (i)
13 wasted costs when shoo-fIy l-ine is removed; (ii) stiLl- exposed
t4 to risk of a single event taking out the non-redundant rebuilt
15 line; (iii) stilI exposed for maintenance on single rebuilt
16 line; (iv) stlll have "most of the same siting issues
77 associated with the permanent downtown Ketchum overhead
18 route"; and (v) difficulty justifying spending $50-80k each
79 for t2 steel angle structures for a temporary line "greatly
t In my direct. testimony (see chart on page 22), I presented
informat.ion regarding the >$25 million savings available for:
(1) a rebuild plus a redundant line versus (2) a rebuild plus
a shoo-fIy line.
HECKLER, DI-REB 6
IDAHO SIERRA CLUB
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increasing the non-recoverable cost of this (shoo-fly)
solution"6 We believe a properly conducted alternatives
analysis could address Mr. Ange11's concern.
A. Do you see other realrons why the shoo-fly
option has been undervalued and ineufficiently anal.yzed in the
current record?
A. Yes. In Rock Rolling Properties LLC's Request
for Production to Idaho Power Company No. 15, the Company was
asked whether the CAC was ever presented with the temporary
10 shoo-f1y option. Mr. Angell's response was, "No, this option
11 was not presented to the CAC as it is inconsistent with the
reliability goal found in Appendi-x C, page 6 of the Wood River
El-ectrical P1an. It states, \Provide redundant transmissj-on
facilities throughout the Wood River Va11ey."'1 That page
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15 (first published December 200'7 ) states that "The first step in
16 developj-ng proposed solutions to the electrical- needs of the
1-7 Wood Rj-ver Valley was to develop a goals document to guide the
18 commj-ttee's efforts to develop and evaluate alternatives." The
19 first bullet under the heading "Re1j-able Power" lists as a
6 Company's Response
Exhibit 319.
? Company's Response
for Production No. 15,
to Staff's Request for Production No. 14,
to Rock Rolling Properties, LLC's Request
Exhibit 320.
HECKLER, DI-REB 7
IDAHO SIERRA CLUB
1 goal, "Provide redundant transmission facil-ities throughout
2 the Wood River Va11ey".8
3 This displays another example of how, by desj-gn, the CAC
4 was not presented with or asked to consider alternatives to
5 redundancy. Redundancy was the stated goal and the CAC was not
5 allowed to veer off that path.
7 Q. Do you think Staff properly analyzed Ida,ho
8 Power's approach to handling ttre Ii-mited risk associated rith
9 unlikeJ.y but catastrophic events?
10 A. Not entirely. As I explaj-ned in my direct
11 testimony, in the past 37 years there hasn't been a single
72 December or January outage caused by the Hailey-Ketchum line
13 that lasted more than 10 mlnutes and there is no seasonal
14 pattern 1n the unplanned outages that have occurred. When
15 Idaho Sj-erra CIub asked how the Company would respond to
16 another outage on both the Hagerman and Gooding lines, the
L"7 Company said that if both lines feeding the VIDRI substation go
18 down they would "restore service as quickly as possible
19 following prudent utility practices of testing, isolati-ng
8 Wood River Electric Plan Appendix C at Page 6, Exhibit 321.
HECKLER, DI_REB 8
IDAHO SIERRA CLUB
1 failed device(s), restoring the remaining system and repair or
2 replacement of the failed device(s)."e
3 We take from this response that the Company would use
4 best practices when faced with a 1ow probability event like a
5 simul-taneous outage on both the l-lnes feeding the WDRI
6 substation. When the Company performed their "analysis" of
7 DERs as alternatives to building a redundant line they assumed
8 that all load must be backed-up. But, based on my discussions
9 with an INL expert, best practj-ces call for backup focused on
10 critical- loads when faced with very Iow probability outages.
11 As it was explained to me, when the outage probability gets
L2 down to "five nines" (meaning a l-ess than 99.9992 probability
13 of occurrence, such as the existing Hailey-Ketchum line has
74 provided), best practice focuses on backing up crj-tical- Ioads
15 under those conditions rather than al-l load. The expert also
16 noted that some national security rel"ated systems such as
7'7 radar or missile defense systems warrant a total- l-oad back-up
18 approach even at that 1ow outage risk 1eve1. Thus, total load
L9 back-up for the NWRV may not be a necessary or cost effective
20 pursuit in the context of preparing for some low probability
2L outaqe events.
9 Company's Response to Idaho Sierra Cl-ub's Request for
Production No. 9, Exhibit 322.
HECKLER, DI_REB 9
IDAHO SIERRA CLUB
1 We believe the record would benefit substantially from
2 some additional- information showing how to address the
3 unlikely outage events with a combination of a rebuilt line
4 along the existing line route supplemented with some loca1
5 backup sources of generation and/or storage. Consideration of
6 such alternatives is necessary to understand the costs and
7 benefits of the redundant line the Company has proposed and
I whether a redundant line is in the public interest.
9 Q. Are you concerned wittr any eJ.aents of Staff's
10 analysis related to ttre ttrird question, "Ifhat costs should be
11 borne by the general body of Idaho Power ratepayers?"
12 A Yes. I have concerns that both cost
13 effectiveness ("least cost") and cost allocation analyses are
L4 included in Staff testj-mony. Rather than just limiting the
15 review of cost matters to the al-location of costs between
L6' local and general ratepayers (as the phrasing of the third
17 question implies to me), I think it is vital that we consider
18 both cost aI]ocation and cost effectiveness issues.
19 Do you see fJ.ars in ttre Staff's conclusion that
20 DERs are aot cost effective?
2L A Yes. Mr. Morrison's testimony provides a
22 conclusion regarding DERs that could be misconstrued. He says,
23 "CAC members requested that the Company evafuate various local
24 generation and storage options as alternatives to a redundant
HECKLER, DI_REB 1O
IDAHO SIERRA CLUB
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1 line. These options included diesel generation, gas turbine
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generatJ-on, biomass generation, solar generation, and battery
back-up. The Company determined that t.he costs of each of
these options exceeded the costs of the Company's proposed
transmission line. I concur with the Companyrs assessment.
Furthermore, as I noted earlier, there is no compelling case
for redundancy.tto
Irrespective of whether Mr. Morrison believes DERs are an
appropriate alternative to a redundant line, they should at
least be revj-ewed as: (1) a method for limiting the harm that
could be caused by unlikely but catastrophic outages
(sabotage, plane crash, earthquake); and (2) a supplement to
the reliability provided by a rebuilt existing line.
A. Please explain the problene rith t.tr. Morison's
conclusion that DERs exceed ttre costs of the Corpany's
proposed traasmission line.
A. A major problem I see is that the Company's
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18 analysis upon which Mr. Morrj-son relies in making his
19 conclusion fail-ed to consider the value of benefits that
20 installing DERs (e.9. generators or storage) coul-d provide
2t both in the NWRV and to the larger system. Such investments
22 can mitigate the severity of outages that do occur and as such
HECKLER, DI-REB 11
IDAHO SIERRA CLUB
10 Morri-son Direct at 25.
1 are a viable option for the Company to reduce the "hurt"
2 caused by impacts from outages. Shortening the duration and/or
3 location of outages is a cost-effective method for reducing
4 impacts.
5 Indeed, when it is in the Company's interest it has
6 considered al-ternatives that would address the impact of
7 outages rather than thej-r elimination. As Mr. Morrison notes,
I Idaho Power explains that the Overhead Distribution route wifl
9 not decrease the frequency of outage events but could decrease
10 their duration. "11
11 Compared to a redundant transmission line that would only
72 be useful in a narrow set of clrcumstances, DERs can serve
13 multi-pIe purposes. Other benefits that do not appear to be
14 valued in Staff's conclusion are: (i) the potential use of
15 DERs as offsets providing savings against future voltage
L6 control improvements that are projected to be needed at the
L7 Ketchum substatisn;12 and (ii) providing ongoj-ng grid servj-ces
18 l-ike peak power shifting and emergency power.
19 A. Do you have concerns rith the cost allocation
20 and least cost analysis Staff perforued?
11 Morrison Direct at 21 (citing Application at 22).
L2 Company's Response to Idaho Sierra CIub's Request for
Productlon No. 5, Exhibit 323,
HECKLER/ DI-REB 12
IDAHO SIERRA CLUB
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A We agree wlth Staff in pointing out the
inappropriateness of using the Company's "standard overhead
distribution" as the baseline agai-nst which to compare the
cost of a partially overhead/partially buried l-ine. We also
agree with the conclusion that should the redundant line be
approved, the benefitted cities/countj-es should bear the full
cost of aesthetic mitigations such as undergrounding. But we
don't believe Idaho Power can show that their proposal is the
Ieast-cost (or even the most reasonable cost) option because
10 the only options they presented were based upon building
11 redundant lines and the need for redundancy has not been
72 shown.
13 Item #3 on Mr. Morrison's
L4 should be borne by the general
l-ist of questions ("What costs
body of ldaho Power rate
15 payers?") needs to be viewed not just in the light of an
between all- ratepayers and16 appropriate allocat.ion of costs
77 benefitted locals, but more generally in the conLext of what
18 j-s a reasonable cost for general ratepayers to ensure reliabLe
19 service to the NWRV. In his testimony Mr. Morrison states,
20 "the burden is on the Company to show that its proposal is
2l necessary, and that it represents the least expensive means
22 for providing relj-ab1e electric power to its customers."13
HECKLER, DI-REB 13
IDAHO SIERRA CLUB
13 Morrison Direct at 26 (emphasis added).
1 Mr. Morrison also states, "In short, a second Wood River-
2 Ketchum line is a very expensive means to achieve a relatively
3 small reliability improvement."l4 We agree. The record simply
4 does not have the information necessary to properly conclude
5 that any option presented by the Company is the least-cost or
6 most cost-effective option. I assert that this docket does not
7 support a concl-usion that any of the discussed options are the
I least-cost or most cost-effective because significant,
9 necessary data is missing. The results of a properly designed
10 study, perhaps 1ed by a technical review committee, will tell
11 us whether there is a lower cost al-ternative that has not been
12 consi-dered. Until data on the cost and benefits of
13 alternatives such as rebuil-ding the existing line and
L4 supplementing it with some combj-nation of DERs to mitigate the
15 effects of Iow probability outages is provided, the Company, s
76 proposal cannot properly be characterj-zed as the lowest-cost
L7 alternative.
18 A. P1ease surnmarize your rebuttal testimony simply.
19 A. We agree with Staff testimony on many points
20 including that: (1) there is no compelling reason to build the
2l proposed redundant line; (2) that the existing line is nearing
22 the end of its useful l-ife and should be rebuilt; and (3) that it
23 makes sense to use a temporary shoo-fIy line to provide power
HECKLER, DI_REB 14
IDAHO SIERRA CLUB
la Morrison Direct at 11.
I while re-building the existing l-ine. [Ie previous]y test.ified that
2 re-building the existing line (including the cost of the
3 temporary shoo-f1y line) is much more cost efficient than both
4 building the proposed new line and re-building the existing 1ine.
5 We also agree with Staff's contention that even if the
5 existing line is rebuilt there remains some residual reliability
7 risk based on low probability events. However, we think Staff's
8 analysis of DERs inappropriately ignores value available from
9 some smafler amount of local generation and storage than the
10 Company reviewed. Especially if focused on supporting critical
11 1oads, Iocal DERs conrlcined with a re-bui.l-t line could provide the
L2 most cost-effective method for addressing the reliability
1-3 implications associated wj-th the type of Iow probability outage
L4 events.
15 Staff identified the problem but did not suggest an
16 analysi-s of alternatives. We think that represents a mistake. The
l7 Company asks that the Commissj-on find that the redundant line is
18 "necessary". Vile don't think the record supports such a findlng,
19 but simply giving a "thumbs-down" to their request seems an
20 inadequate resolution. The CAC members worked diligently to
2L address NWRV reliabili-ty concerns, but the CAC process was run in
22 such a way that it effectively only addressed redundant line
23 based solutions. We believe both the CAC and the larger public
24 deserve a different resolution to this docket. The data currently
25 in the docket do not support the analyses needed to resolve the
HECKLER, DI-REB 15
IDAHO STERRA CLUB
1 open cost and benefit issues listed above. Idaho Sierra Club
2 believes the public
3 the establishment of
4 mechanism to collect
5 Q. Doeg
6 nor?
7 A. Yes.
interest would be best served by directing
a technical advisory councj-I or other
the data needed to resolve these issues.
this aonclude your rebuttal teatimony for
HECKLER, Dr-REB l_6
IDAHO SIERRA CLUB
CERTTFTCATE OF SERVICE
I hereby certify that on this 23'd day of June, 201.7, T served
the foregoing as follows:
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IDAHO SIERRA CLUB
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Kelsey Jae Nunez
Attorney for Idaho Sierra Club
HECKLER, DI-REB 18
IDAHO SIERRA CLUB
BETORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDATIO SIERRA CLT'B
HECKLER, DI.REB
TESTIMONY
EXHIBIT NO. 319
REQUEST NO. 14: On page 19 of its Application, the Company explains that
the overhead transmission line route through the Ketchum Elowntown District would
depend upon the condemnation of private property. Please provide the Company's
estlmates of condemnation costs of the Overhead Transmission line route through the
Ketchum Downtown District.
RESPONSE TO REQUEST NO. 14: As stated in the Company's Application,
"Neither of the two possible route options for an Overhead Transmission construction
configuration [Dollar Mountain or E]owntoum Districtl provides a viable solution for
redundant electric service to the North Valley." Application at 20. As further explained
on pages 18-19 of the Application:
The North Valley exhibits several transmission siting
obstacles for overhead access to the existing Ketchum
substation. First, the North Valley is congested due to
numerous residences and businesses sited in a valley less
than one mile wide with mountains of steep slope and
narow rcadways. This would force an overhead
transmission line either through the downtown district of
Ketchum or over the top of Dollar Mountain and spanning
down over existing homes nearthe substation. . . .
The line route across Dollar Mountain would be limited to a
double circuit on @mmon tower configuration with the
existing 138 kV transmission line from Elkhom substration to
Ketchum substation. This @mmon tower oonstruction has a
high probability of resulting in the simultraneous loss of both
transmission circuits should a failure occur, resulting in North
Valley customer outages for the Line Events. This fact alone
defeats the purpose and need of constructing a redundant
source of energy to improve the reliability of seMce, and is
therefore not a viable option. Additionally, condemnation of
private property may be required to enter the Ketchum
substation overhead from Dollar Mountrain. Finally, North
Valley customers uould likely strongly oppose this option
due to the visual impacts. This option would not provide an
independent and fully redundant transmission souroe to the
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCT]ON REQUEST OF THE COMMISSION STAFF - 4
Ketchum substations nor meet the purpose and need where
the other options discussed below trtlould.
The Overhead Transmission line route thmugh the Ketchum
downtown district would have significant challenges. The
challenges include the fac't that the City of Ketchum is set up
with a grid of streets, sidewalks, and zero setback buildings.
Options that exist for construction of overhead transmission
include placing the poles in the sidewalks, the edge of
streets, and overhanging the wires over the streets,
constructing tallenough structures to span the wires overthe
tops of buildings, and utilizing side streets. Because of the
very tight geographical constraints, thls option would likely
be dependent upon and require condemnation of private
property in orderto pass through downtown Ketchum with an
overhead line to the Ketchum substation. Again, North
Valley customers, in particular Ketchum customers, would
strongly oppose this option on visual impacts alone.
However, ldaho Power has made some preliminary assessments of the potential
costs to be incuned in providing redundant electric service to the North Valley through
an overhead transmission option. The Overhead Transmission line route through the
Ketchum Downtown District would be located primarily in the public road rightof-way,
with the steel transmission poles located at the outer edge of the right-of-way. lf ldaho
Power were to use its TR (triangular) configuration for the 138 kV transmission line that
is proposed for other overhead portions of the transmission line (please see Attachment
1 provided on the enclosed CD), one of the transmission line insulators (approximately
five feet long) and the transmission line conductor attached at the end of the insulator
would extend out over the adjacent private property. This would require ldaho Power to
obtain an overhang easement over the private property for the insulator and conductor
along the length of the transmission line
As an altemative to the TR configuration, ldaho Power could employ a TA
(tangent angle) transmission line configuration where all three transmission line
IDAHO POWER COMPANYS RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF - 5
insulators and conductors are placed on the road side of the power line (please see
Attachment 1). The TA poles (approximately 60 feet tall) are roughly 10 feet taller than
TR ples (approximately 50 feet tall) in order to provide sufftcient spacing for the three
insulators and conductors on the same side of the pole. However, even wtth all three
insulators extending to the road side of the pole, the TA configuration could still require
overhang easements on the adjacent private property because there would not be
enough horizontal clearance from the conductors to a building constructed at the edge
of the adjacent private property (wtrich would be possible with the zerc setback
requirements in the Ketchum Downtown District).
ldaho Power has also reviewed engineering options for avoiding the transmission
line overhang and clearance requirements through the Ketchum Downtown District.
Idaho Power could add three cross-arms to make a modified TA configuration called a
"Davit Arm" struc-ture in order to extend the three onductors further out into the road
right-of-way (please see Attachment 1). The Davit Arms would be approximately 12
feet long and each arm would have six-foot long insulators attached at the end of the
arm (to guide the energized conductor wire away from the end of the arm). ln some
cases this would cause the 12-foot arm plus the six-foot insulator extending directly out
frcm the arm to create a combined horizontal extension arm of 18 feet. This Davit Arm
mnfiguration would eliminate the need for overhang easements or clearance space with
respect to the adjacent private property. However, the Davit Arm design is visually
more intrusive than the TR or TA designs as shown on Attachment 1. A photograph of
the Davit Arm oonfiguration is also shown on Attachment 2 provided on the enclosed
CD. ldaho Power does not believe the Davit Arm design would be a viable option for
the overhead transmission line route through the Downtown District because the North
IDAHO POWER COMPANYS RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF.6
Valley customers, ln particular Ketchum customers, would strongly oppose this option
based on its visual impacts alone. Additionally, the placement of so many non-standard
structures in such close proximity to roads and zero setback bulldlngs is simply not a
viable routing solution.
ldaho Power has not determined how many overhang easements on private
property would be required for the ovefiead transmission line route through the
Ketchum Downtown District under a TR or TA transmission line configuration. This
determination would require survey, design, and engineering of the rcute to establish
the specific locations of the transmission poles within the road right-of-way (or
potentially in some cases, outside road rightof-way), followed by an assessment of the
overhang and clearance impacts of the transmission line on the adjacent private
property. Horruever, ldaho Power did identiff the private parcels adjacent to the
overhead transmission line route through the Ketchum Downtown District that could
possibly require overhang easements. A list of those parcels and their respective
assessed values are provided on the enclosed CD as Attachments 3 and 4.
Of the 20 prcperties identified in Attachments 3 and 4 related to the Downtown
District route, the assessed values range from a low of approximately $13,000 to a high
of approximately $2.6 million. Four of the 20 identifted propertles show a zeno-assessed
value because they are Church-owned properties. The approximate total assessed
value of the remaining 16 properties exceeds $19.4 million. The estimated value of the
undeveloped land across Dollar Mountain is approximately $10/square foot. One
approximation for estimating the value of an easement is 50 percent of the market value
for the portion of the parcel required for the right-of-way. Under this approximation, the
estimated 100 foot wide easement mst for the two-mile portion across Dollar Mountain
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF .7
is $5,420,000. The last span of line required of the Elollar Mountain route that enters
the Ketchum substation crosses four parcels in a developed residential subdivision in
Sun Valley. These parcels have a combined assessed market value of $7,311,2M.
ldaho Power is unable to determine at this time what the easement valuation
would be for overhang easements crossing the parcels listed on Attrachments 3 and 4
for the Downtown District route, and is unable to detennine at this time what the
valuation of possible condemnation of required right-of-way would be valued at for
either the Downtown District route or the Dollar Mountrain oute. Relevant factors vrould
include the width of the easement strip, the existence of buildings or other
improvements wtthin the easement strip, and the "severance" impact on the remainder
of the private parcel adjacent to the easement strip. Property owrcrs could seek much
higher levels of compensation for the ldaho Power transmission line easements in a
condemnation proceeding. Condemnation damages are typically calculated based on
the value of the owne/s property before and after the condemnation taking. This
includes the diminution in value to the easement strip and also any "severance'
damages to the remainder of the owne/s property outside of the easement. ln addition,
the property owner would seek to recover his or her legal expenses from ldaho Power
for the condemnation proceeding, wtrich may or may not be recoverable depending on
the amount of the condemnation award compared to ldaho Powefs final offer for the
easement acquisition. ldaho Power would also incur its own outside legal counsel
expenses for representation in the condemnation proceedings. Added to the potential
cost and liability of oonstruction of tmnsmission lines and structures in such close
proximity to tall buildings and other improvements upon the real property impacted
thereby, is the potentialfor claims of inverse condemnation, which could be very costly.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REOUEST OF THE COMMISSION STAFF. S
Based on these multiple variables, ldaho Power cannot provide a meaningful estimate
of the cpst of condemnation for either the Downtown District or the Dollar Mountain
oute. However, based upon the nature of the structures and impovements that exist
on the parcels through downtown Ketchum and around the Ketchum substation, as well
as the very high assessed property values of the same, combind with an unknourn
future brX potentially costly liability associated with inverse condemnation claims, the
practicalities of actually obtaining the required easements, by condemnation or
othenruise, could be extremely costly and is simply not reasonable and prudent.
Because a more precise estimate of potential easement costs tllould require
significant additional work, cost, and evaluation (as stated above, this would require
among other things survey, design, and engineering of the route to establish the specific
locations of the transmission poles followed by an assessment of the overhang and
clearance impacts of the transmission line on the adjacent private prcpefi) and
because both overhead route options werc determined to not be viable solutions for
redundant electric seMce to the North Valley, no further investigation of these costs
was done. The additional unknown costs of possible condemnation would not be
known with more certainty until the Company was at the point of actually pursuing
condemnation. Furthermore, the extent of exposurc to possible claims of inverse
condemnation would be an additional potentially very costly liability moving fonrard after
such a line were constructed.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANYS RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
BETORE THE
IDAT{O PT'BI.IC UTTLITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDATIO SIERRA CI,T'B
HECKLER, Dr-REB
TESTIMONY
EXHIBIT NO. 324
REQUEST NO. 15: Reference the Companfs Response to Sierra Club
Production Request No. 4, regarding the costs of the temporary shoe-fly line that would
allow reconstruction of the existing 138 kV Wood River-Ketchum line. Was this option
presented to the Community Advisory Committee (CAC)? Please provide all
documents dernonstrating this option was presented to the CAC and the CAG's
response that this option was unac@ptable.
RESPONSE TO REQUEST NO. 15: No, this option was not presented to the
CAC as it is inconsistent with the its reliability goal found in Appendix C, page 6 of the
Wood River Electrical Plan. lt states, "Provide redundant transmission facilities
throughout the Wood River Valley."
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 SET OF
PRODUCTION REQUESTS OF ROCK ROLLING PROPERTIES, LLC - 22
BEFORE THE
IDAIIO PT'BI,IC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAIIO SIERRA CI,T'B
HECKLER, DI.REB
TESTIMONY
EXHIBIT NO. 32L
a
ldaho Power Company
Goals Document
The first step in developing proposed solutions to the electrical 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 evaluate
alternatives. The goals were divided into 6 areas:
Reliable Power: Provide reliable power to the entire Wood River Valleyo Provide redundant lransmissionfrcilities throughout the Wood Rtver Valleyo Provide sfficient reliable, quality power necessary to support the Valley's ctrrent andfuture business
and economic aclivitiesc Include Lincoln and Camas counties' electricity needs
New Infrsstructure Desisn: Develop new transmission and delivery infrastructure as
appropriate when providing for current and future power needs. Optimize the use of existing infrastrrcture: increase use or upgrade as feasiblec Implementfeasible mechanical alternattves to new transmission or delivery systems to provide
redundancyo ldentify and utilize alternative and renewable sources of power that minimize the needfor new
transmis s iory'de I ivery infrastruc twec Plan and implement infrastrtrctwe improvements that integrate withfuure syslem developmento Explore and implement new power system technologies asfeasible and appropriate
Enerw Conserration: Implement programs that reduce demand for additional energy. Implementfeasible "Demond Side Monagemenl" programs lo redtrce power demand as a portion of an
overall solulion lo meel the Valley's energt needso Optimize the use of existing "conservation" programs asfeasible to reduce power demand. Develop new "conservation" programs wilh educalion, asfeasible and supported by Valley residents
Environment: Cause no or minimum impacts to the natural, physical, cultural, historic, social
and aesthetic environment due to development and operation of power facilities and delivery
systemso Utilize existing/shared utility and transportalion corridors wherefeasibleo Slte new corridors that hove no or minimal impact on the environmento Preserve the Wood River Valley's oeslhetic and scenic qualities
Political Sunoort: Develop solutions that are politically supported throughout the Wood River
Valleyt Address individual and collective polilical concerns for design, operation, siting and fundingt Integrate WREP recommendation into local land use plans; comply with local plans if possibleo Consider the least obtrusive and least objectionable option lo enhance opportwrityfor public support
and implementation
Cost Effectiveness: Develop solutions that arc cost effective and provide associated benefitso Implement solulions that are ffirdable to construct. Implement solutions that are affordable to operate utd maintaino Cause no or minimun rale increoses to support new infrastrrclwe/system improvementso Minimize local public or privatefwtding particiption or support new or upgraded infrastructweo Implement solutions that have available public or privatefundingwhere required
a
a
a
o
a
Updated May 201I
Wood River Electrical Plan
AppendixC-Page 6
Exhibit No. 2
Case No. IPC-E-16-28
D. Angell, IPC
Paoe 43 of 92
BETORE THE
IDAIIO PT'BLIC UTILITIES
COMMISSION
cAsE NO. rPC-E-16-28
IDAIIO SIERRA CLT'B
HECKLER, DI.REB
TESTIMONY
EXHIBIT NO. 322
REQUEST FOR PRODUCTION NO. 9: Please describe the Company's plans
for serving the North Valley in the event the reconstructed line and potential new
redundant line experience outages at the same time due to "Line Events" or other
causes such as that which resulted in the December 2009 loss of power to the WDRI
substation.
: ln the low probability
event that both lines sourcing the North Valley experience outages at the same time or
there is a loss of power to the Wood River substation, the Gompany will restore service
as quickly as possible following prudent utility practices of testing, isolating failed
device(s), restoring the remaining system, and repair or replacement of the failed
device(s).
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.12
BEFORE THE
IDATIO PT'BI,IC UTILITIES
COMMISSTON
cAsE NO. rPC-E-16-28
IDAIIO SIERRA CLT'B
HECKLER, DI.REB
TESTIMONY
EXHIBIT NO. 323
REQUEST FOR PRODUCTION NO. 5: ln the 2011 Wood River Electric Plan,
ldaho Power projected that in Year 15 it would be necessary to "add new voltage control
device at Ketchum substation.' Exhibit No. 2 to David Angell's Direct Testimony at77
of 92, Appendix H. What does the Company proiect will cause the need for
improvement to voltage control at the substation in that timeframe? What devices might
meet these needed improvements?
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: The Company
forecasts the peak load served by the Lincoln, Silver, Hailey, Ketchum, Elkhorn,
Moonstone, Toponis, and Pocket substations to increase to a point requiring additional
voltage support at the Ketchum substation in order to supply proper voltage to the
customers served by Ketchum and Elkhom substations. The Company plans to instal! a
shunt capacitor bank, which may be switched into service during the peak loading
conditions, to increase the voltage at the Ketchum and Elkhorn substations.
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 - 8