20220111Reply Comments.pdf

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AnD OOIpComp.ny
January 11,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (837'14)
PO Box 83720
Boise, ldaho 83720-007 4
Re Case No. IPC-E-21-25
ln the Matter of the Application of ldaho Power Company's Petition for
Approval of a Customer Surcharge and Modified Line Route Configuration
for Construction of a New 138 lry Transmission Line in the Wood River
Valley
Dear Ms. Noriyuki:
Enclosed forelectronicfiling, please find ldaho PowerCompany's Reply Comments
in the above matter. PIease feelfree to contact me directly with any questions you might
have about this filing.
Very truly yours,
DONOVAN WALKER
Lead Counsel
[e-mail]
DEW:cld
Enclosures
h,*Zdall --
Donovan E. Walker
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa lke [e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UT!LITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION
FOR APPROVAL OF A CUSTOMER
SURCHARGE AND MODIFIED LINE
ROUTE CONFIGURATION FOR
CONSTRUCTION OF A NEW 138 KV
TRANSMISSION LINE IN THE WOOD
RIVER VALLEY.
CASE NO. IPC-E-21-25
IDAHO POWER COMPANY'S
REPLY COMMENTS
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ldaho Power Company ("ldaho Powe/' or "Company"), in accordance with RP 201, et
seg., as well as the ldaho Public Utilities Commission's ("IPUC" or "Commission") Notice of
Modified Procedure in this matter, Order No. 35244, hereby respectfully submits the following
Reply Comments in the matter of the Company's petition for approval of a customer surcharge
and modified route configuration for construction of a new 138 kilovolt ('kV') transmission line
("Transmission Line") project in the Wood River Valley.
I.INTRODUCTION
ln these Reply Comments, ldaho Power responds to Staffs, Cox Communication's, and
Kiki Leslie A. Tidwell's review and comments, as well as the comments received from customers
located in Blaine County. The proposed modified line route and build configuration for the
proposed transmission line, along with the proposed surcharge mechanism described in the
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
Company's Petition, represents the culmination of more than a decade of planning and
collaboration with Blaine County. Approval of the recommendations presented in this case will
serve the public interest and support ldaho Poweds efforts to provide safe, reliable, and fair-priced
electric service to its customers. The Company appreciates Staffs thoughtful and complete
evaluation of comments received in this case. Staff identifies and correctly categorizes the stated
objections to this project. Staff also acknowledges that this project has been a collaborative effort
between the Company and Blaine County, resulting in a reasonable proposalfor moving fonrard
this important transmission line project.
II. REPLY COMMENTS
A. ldaho Power Replv to Staff Comments
ln its Comments, Staff recommends that after its thorough review of the Company's
requests, the Commission approve the proposed surcharge and line route modifications. Staff
Comments, p 3.
After a thorough review of all information available, Staff is generally
supportive of the Company's Petition. Staff believes that the
Company's collaborative work with Blaine Coun$ representatives
achieved a reasonable line configuration and project financing
alternative. lmplementation of a Blaine County surcharge provides
the least consequential impact on the general body of rate payers
and Staff recommends that the Commission approve it.
Id. More particularly, Staff recommends that the Commission:
1. Approve the Company's proposed CPCN modifications (Owl
Rock Road Route) as described in the Petition.
2. Approve the Company's proposed surcharge and Schedule 96
as filed and order the Company to file, upon project completion,
a revised Schedule 96 if cost changes require Schedule 96 to
be modified.
3. Approve the Company's request for an Accounting Order
authorizing the accelerated depreciation of the incremental
capital costs to match the 20-year surcharge period.
4. Order the Company to clearly labelthe surcharge as its own line
item in billing statements for its Blaine County customers.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
5. Order the Company to provide the estimated cost of the Owl
Rock Road Route when it receives final pre-construction pricing
information for the project.
6. Order the Company to file, not more than 6 months after the
project has been completed, a finaldetermination of the original
CPCN route cost and the incremental project cost for the Owl
Rock Road Route for review and approval along with any
necessary changes to the proposed surcharge if any.
ld., at p 12-13.
The Company accepts and supports each of Staffs recommendations. Staff Comments
also included a discussion of lifecycle and operations and maintenance ('O&M') costs and a
calculation of a potential small ratepayer ("customef') impact. The Company agrees with Staffs
recommendation that there be no adjustments related to their customer impact calculation. As
Staff notes, the calculated impact on other customers is expected to be negligible. The Company
agrees with Staffs suggestion that if similar requests for undergrounding are made in the future,
the incremental lifecycle and O&M costs will be included in the Company's analysis and, if
significant, included for recovery from municipalities.
B. Cox Communications Comments
Cox Communications ("Cox") has a communications line ('Communications Line")
attached to the ldaho Power overhead distribution line that will be buried as part of the
Transmission Line project. The ldaho Power distribution line extends approximately eight miles
along Buttercup Road and Highway 75 as shown on Exhibit 3 to the Direct Testimony of Ryan
Adelman in the Company's initialfiling in this case. Cox has indicated that it plans to relocate the
Communications Line onto ldaho Power's new overhead transmission Line that will be installed
in the same approximate location as the distribution line under the Transmission Line project.
While ldaho Power is not required to provide space on the Transmission Line for the new
Gox attachments, the Company has worked cooperatively with the Blaine County Board of County
Commissioners ("County Board") and Cox to provide a Transmission Line configuration option
that would provide space for the Cox attachments on the Transmission Line poles. This
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
Transmission Line configuration is based on an engineering study conducted by ldaho Power's
contractor, HDR Engineering, to determine what Transmission Line modifications would be
needed to allow for the attachment of the Cox Communications Line on Transmission Line poles
10 through 165. The HDR Engineering study established the clearance requirements for the
Communications Line attachments on the Transmission Line poles and determined that 19 of the
156 Transmission Line poles in question would need to be raised to provide sufficient clearance
for the Communications Line attachments. ldaho Power submitted the HDR Engineering study
as Exhibit C2 in the County Board conditional use permit proceedings for the Transmission Line
and attached to Cox's comments in this case.
The County Board approved the Transmission Line configuration based on Exhibit C2 in
its Findings of Fact, Conclusions of Law and Decision dated March 15, 2021, granting ldaho
Power a conditional use permit ('CUP) for the Transmission Line. The CUP included a
Conditions of Approvalsection, with No. 18 stating:
18. Cox Communication shall have access to lease for a single
communications wire only on the above ground transmission line,
including raising up to 19 poles to match heights and locations
described in Exhibit C2.
The Cox comments submitted to the Commission also quote from the CUP's Conditions of
Approva! No. 18, and express support for the Transmission Line clearances described in Exhibit
C2:
A copy of Exhibit C2 to the Final CUP for the Owl Rock Road Route
which the Applicafrbn seeks approval is attached hereto. As
provided in Exhibit C2 to the Final CUP, Cox has access to the new
poles, including requiring poles to be heightened from ldaho
Power's original design to accommodate Cox's communication
wire.
ldaho Power has incorporated the Exhibit C2 clearance specifications and pole heights into the
Transmission Line project under the Owl Rock Road Route for which the Company is seeking
Commission approval. Accordingly, ldaho Power believes that it would be appropriate for the
Commission to recognize the ldaho Power-Cox accommodation in its order in this case through
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
a similar general statement as provided in Order No. 33872, Case No. IPC-E-16-28, where the
Commission granted ldaho Power a CPCN for the Transmission Line in2017:
As to Cox's request to continue to attach equipment to ldaho
Power's poles, we understand that ldaho Power's proposed design
for the overhead portion of the line will allow for attachment of Cox's
equipmentwhile keeping pole heightsto a minimum. We appreciate
the willingness of Cox and ldaho Power to work together to find a
solution.
By contrast, ldaho Power would not support a broader requirement in the Commission's
order in this Case that ldaho Power shall provide sufficient space on its Transmission Line poles
to allowthe attachment of the Cox Communications Line. Such a broad requirementwould create
an attachment right that does not presently exist and could force ldaho Power to make additional
and expensive changes to the Transmission Line poles if Cox determines that it would prefer
additional space for its attachments beyond the specified clearances in Exhibat C2. lf the
Commission wishes to provide any greater detail related to the Cox attachments, the reference
should be limited to clearance specifications set forth in Exhibit C2, which the County Board,
ldaho Power, and Cox have previously concurred with to allow for the attachment of the
Communications Line on the Transmission Line.
C. Kiki Leslie A. Tidwell Comments
While Ms. Tidwell addresses a wide range of issues in her comments, ldaho Powe/s reply
is focused on those comments that apply to the Company's proposed Transmission Line project,
which is the subject of this case.
1. Tidwell Paraoraph 2
Ms. Tidwell states that ? strong case has not been made that all ldahoans should pay for
this non-essential undergrounding of transmission lines in the City of Ketchum." This issue was
fully reviewed and decided in the Commission's Case No. IPC-E-I6-28 CCPCN Case"), in which
the Commission granted ldaho Power a CPCN to construct the Transmission Line in Order No.
33872 ('CPCN Order"). ldaho Power's petition and testimony in the CPCN Case reviewed four
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
possible engineering alternatives for the approximately 3.S-mile northern portion of the
Transmission Line route ("Northern Segment"), which extends south from the Ketchum
Substation, through the City of Ketchum, and continuing south to the intersection of Owl Rock
Road and Highway 75. These alternatives for the Northern Segment were: (1) overhead
transmission, (2) underground transmission, (3) overhead distribution and (4) underground
distribution.
Based on ldaho Power's extensive analysis of the four power line engineering alternatives
for the Northern Segment, as described in the Company's petition and testimony in the CPCN
Case, ldaho Power recommended, and the Commission approved in the CPCN Order, the
underground transmission option for the Northern Segment. Under this option, the Transmission
Line will be buried for an approximately 2.2-mile distance extending south from the Ketchum
Substation through the City of Ketchum to the intersection of Elkhorn Road and Highway 75.
Ms. Tidwell states in her comments that the overhead transmission option through the City
of Ketchum would be less expensive than the underground transmission option. However, ldaho
Power documented in its application and testimony in the CPCN Case that the overhead
transmission option was not a viable option through the City of Ketchum. As ldaho Power stated
in its petition in the CPCN Case:
The Overhead Transmission line routethrough the Ketchum
downtown district would have significant challenges. The
challenges include the fact 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 tall enough structures to span
the wires over the tops of buildings, and utilizing side streets.
Because of the very tight geographical constraints, this option
would likely be dependent upon and require condemnation of
private property in order to 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.
Neither of the two possible route options for an Overhead
Transmission construction configuration [including Dollar Mountain
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
route] provides a viable solution for redundant electric service to the
North Valley.
Nothing has changed since the Commission's September 2017 CPCN Order to indicate
that constructing the Transmission Line overhead through the City of Ketchum would be any more
viable today. ln fact, the continuing development in Ketchum would create even greater obstacles
for establishing a viable transmission line route through Ketchum.
2. TidwellParaoraph 3
Ms. Tidwell states that ldaho Power has taken the position that burying "the distribution
lines between Hailey and the hospital" is "non-essential to electrica! service". This refers to the
approximately eight-mile distribution line segment that ldaho Power is proposing to bury as part
of the Company's recommended Owl Rock Road Route. Ms. Tidwell's reference is correct to
state that burying the distribution line is not essentialfor electric service. There are no significant
physical obstacles that interfere with placing the distribution line overhead. The main purpose for
burying the distribution line is to reduce the visual impact of the Transmission Line p@ect.
Accordingly, the incremental cost of burying the distribution line is to be borne by the requesting
party, which in this case involves the surcharge assessment on customer power bills within Blaine
County, as set forth in ldaho Power's petition.
3. Tidwell Paraqraph 4
Ms. Tidwell also questions the cost and redundancy value of the Transmission Line. ldaho
Power provided a thorough description of the reliability need for the Transmission Line in its
petition and testimony in the CPCN Case, and the Commission acknowledged that need in its
CPCN Order. ldaho Power's petition in the CPCN Case states:
ldaho Power generally initiates and constructs a second
transmission source and transformer when a substation peak load
is projected to exceed 40 MW. Recent examples include the
additions of second transmission lines and transformers at the
Victory and McCallsubstations. ldaho Power is also moving fonrard
with a second transmission project in the Eagle and Star area,
which peaks at 71 MW. The Ketchum and Elkhorn substations'
peak load of about 60 MW, coupled with the winter tourism
IDAHO POWER COMPANY'S REPLY COMMENTS - 7
population in the North Valley, strongly supports the need for a
second transmission line. The most significant risk of outage and
economic impact occurs during the peak of the winter season when
the electrical demand and tourism activity peak. Deep snow and
steep terrain can create very difficult access to susceptible sections
of the existing transmission line, resulting in sustained outages
(defined as an interruption that lasts more than five minutes). ldaho
Power currently estimates the existing North Valley transmission
configuration will result in average sustained outages of more than
209 minutes per year. However, an extended outage could last
multiple days and be catastrophic, not only ftom the economic loss
of the area, but the additional damage that may be caused by water
pipes freezing. Summers are not immune from risk either, with the
potential for a fire to take out the existing line, impacting the ability
to pump gas or water, and resulting in economic loss. Multiple
transmission sources are standard practices that ldaho Power
implements to reduce the likelihood of sustained outages.
Additionally, ldaho Power installs distribution circuit tie switches,
where adjacent circuits are available, to reduce the duration of
sustained outages on the radially sourced distribution system.
Ms. Tidwell also indicates that ldaho Powe/s existing 138 kV Wood River-Elkhorn-
Ketchum Transmission Line ("Existing Transmission Line') may need repairs to provide reliable
service. ldaho Power has emphasized the need for comprehensive maintenance and repair of
the Existing Transmission Line, and one of ldaho Power's main objectives for constructing the
Transmission Line is to be able to de-energize the Existing Transmission Line for maintenance
and reconstruction work. Otherwise, performing the planned work on the Existing Transmission
Line would require numerous and extensive outages to customers in the northern part of the
Wood River Valley ("North Valley"), which would not be an acceptable option
Ms. Tidwell also states in Paragraph 4 that "it would be much less expensive to run a
temporary line and repair the first one." This option was thoroughly reviewed in the CPCN Case
ldaho Power's application in the CPCN Case states:
A temporary line to the Ketchum substation would be
required to serve the customers of the Ketchum and Elkhorn
substations during the reconstruction of the existing line. The
temporary line would be placed in road right-of-way, mostly along
Highway 75, to minimize private proper$ impact and right-of-way
costs. The temporary line would almost assuredly be deemed a
visual impact by many North Valley customers. Following the
completion of the reconstruction, the majority of temporary line
IDAHO POWER COMPANY'S REPLY COMMENTS - 8
materials (poles and insulators) would be salvaged; however, the
conductor cannot be salvaged. \Mth the construction of a redundant
138 kV transmission line the reconstruction of the existing line could
be done with little to no disruption of service, and without the lost
investment of installing and removing a temporary line during
reconstruction.
The "Commission Findings and Decision" in the CPCN Order further states:
Nearly all the parties and participants agreed that the
existing line needs to be rebuilt. ldaho Power explained that the
redundant line would allow the existing line to be rebuilt without
interruption to customers. Petition at 16. Other parties and
participants argued that the existing line could be rebuilt using a
temporary line to avoid interruption to customers. Tr. at 531, 603,
632-3 5. Regardless, rebuilding the existing line using a temporary
line instead of a second permanent line does not create redundancy
and thus does not improve resiliency to the North Valley in a
permanent way going fonrard.
lnstalling a temporary transmission line for repairs on the Existing Transmission Line
would not provide long-term transmission redundancy for the North Valley and was accordingly
not recommended by ldaho Power and not adopted by the Commission in the CPCN Order
4. Tidwell ParaoraohsS. 11.12. 14
Ms. Tidwell recommends using alternative energy sources in place of the Transmission
Line. ldaho Power has addressed alternative energy resources at length in connection with the
Transmission Line project, as indicated in Mr. Adelman's testimony (p 13-15) in this case:
O. Did ldaho Power explore alternatives for the
Transmission Line?
A. Yes. ln addition to conducting the transmission
evaluation through the \tVREP [Wood River E]ectric Planl planning
process, ldaho Power worked with the WREP CAC [Citizens
Advisory Committeel, the Wood River Renewable Energy Working
Group, and the Ketchum Energy Advisory Committee to review
other potential energy sources to provide backup power for the
North County. Based on this review, ldaho Power produced a report
entitled Northern Wood River Valley-Local Backup Electrical Supply
Report in October 2015 ("Backup Power Report"). The report was
further updated in November 2016.
The U.S. Department of Energy's ldaho National Laboratory
(which has more than 1,000 megawatts of hybrid power, solar, and
IDAHO POWER COMPANY'S REPLY COMMENTS - 9
wind energy systems deployed at Department of Defense and
industry/utility sites around the world) provided independent
technical review and feedback for the Backup Power Report.
The Backup Power Report analyzed diesel generation,
natural gas generation, and solar generation as potential backup
power sources, after determining that wind generation, geothermal
generation, and biomass generation were not viable alternatives for
the WRV.
The installation costs and the annual maintenance costs,
respectively, for the three backup energy sources analyzed in the
Backup Power Report would be significantly higher than the
installation and maintenance costs for the Transmission Line. The
alternative backup power cost comparisons to the estimated $30
million Transmission Line are as follows: Diesel Engine ($57 million
total installation cosU$1 million annual operations & maintenance),
Gas Turbine ($101 million/$0.455 million) and PV plus Battery
Storage ($gZa mi[ion/$3.45 million).
O. Did ldaho Power revisit the costs used in the Backup
Power Report to determine if alternatives were viable?
A. Yes. ldaho Power reviewed the Backup Report and
determined that, while the cost of alternative energy technologies
has gone down since the Backup Report was developed, the
outcome remains the same - the Transmission Line remains by far
the most cost-effective solution to provide the North County with
reliable electric service.
Ms. Tidwell indicates in Paragraph 5 that ldaho Power has identified future battery storage
acquisitions in its 2021 lntegrated Resource Plan ("lRP") and recommends the installation of
battery storage at the ldaho Power substations "north of the hospital" in place of the Transmission
Line. Ms. Tidwell is correct that ldaho Power has included the installation of battery storage
facilities at selected distribution substations in its service area that are nearing maximum load
capacity (of up to 5 megawatts ("MW) per substation) in its latest lRP (filed in Case No. IPC-E-
21-43). ln these select cases, battery storage would provide additional capacity more
economically than adding or replacing transformers at the substations. However, as the Company
has previously addressed, adding battery storage for backup power to the North Valley in place
of the Transmission Line would require far greater battery capacity, and is not a practical or cost-
effec-tive option. The Transmission Line would provide 60 MW of capacity, sufficient to serve the
IDAHO POWER COMPANY'S REPLY COMMENTS - 10
entire North Valley in the event of an outage on the Existing Transmission Line. Adding 60 MW
of battery capacity in place of the Transmission Line would not only be very expensive, but would
only supply backup power for a limited time, typically 4-6 hours. As explained previously by ldaho
Power in the CPCN case, an outage on the Existing Transmission Line could last for days
depending on weather conditions, terrain, and the extent of damage to the Existing Transmission
Line. A backup battery system could not realistically supply the quantity and duration of power
needed to continue service to the North Valley for such an outage.
5. TidwellParaoraph 6
Ms. Tidwell asserts that the proposed surcharge to fund a portion of the Transmission Line
project undergrounding is regressive and will not benefit Blaine County homeowners in areas
such as Carey. ldaho Power provides a thorough description of the surcharge and surcharge
development in its petition. As described in the Company's petition, Blaine County reviewed a
number of possible funding sources for the Transmission Line burials, including bond issuances,
levy overrides and local improvement district assessments. Blaine County determined that these
measures were not satisfactory funding sources for Transmission Line undergrounding.
Blaine County then inquired about billing surcharge options by ldaho Power to provide
funding for Transmission Line burials. ldaho Power agreed to review a surcharge altemative with
the County, provided that the surcharge would not exceed a total surcharge level of 3 percent-
similar to the 3 percent maximum franchise fee in ldaho. After reviewing the surcharge alternative,
and after conducting a poll of Blaine County citizens, Blaine County expressed support for the
equivalent of a 3 percent franchise fee on all Blaine County customers, which would pay to bury
the Existing Distribution Line and the 1.4-mile segment of the Transmission Line between Elkhorn
Road and Owl Rock Road over an estimated 2O-year period. ldaho Power agreed to pursue the
surcharge in this case.
ldaho Power's petition and accompanying testimony in this case provide detail on how the
proposed monthly surcharge assessments were calculated and how the final costs of the
IDAHO POWER COMPANY'S REPLY COMMENTS - 11
Transmission Line project undergrounding will be determined. ldaho Power believes that, as a
whole, the surcharge as proposed would provide a reasonable balance for the collection of
undergrounding costs from the Company's customer classes in Blaine County.
The Company also addressed the type and structure of the surcharge in its petition and in
the direct testimony of Tim Tatum (p 16):
Q. How did the Company determine a fixed/flat monthly
amount was the appropriate surcharge model?
A. The Company began by assessing several potential
options (e.9., charges that would be fixed, variable, or assessed
based on individua! customer characteristics). Because the costs of
undergrounding are not associated with energy use or demand, the
Company settled on a flat charge as the most appropriate and
reasonable type of charge. Further, ldaho Power cannot assess a
charge based on information the Company does not possess such
as customer property size/value or customer income level.
Additionally, and importantly, flat charges are transparent,
predictable, and easy to understand by customers.
6. Tidwell Paraoraphs 9 and 10
Ms. Tidwell criticizes ldaho Powe/s financing charge used for the proposed Surcharge
assessments ('...the extra egregious -10% interest rate charged by ldaho Power to Blaine
County residents for undergrounding distribution lines between Hailey and the hospital"). ldaho
Power describes the surcharge assessment calculation in Mr. Tatum's testimony (pp 14-15)
Q. Using annual billed revenue as the basis of collection, how much
would ldaho Power collect over a ZO-year period?
A. The net present value of the 20-year surcharge based on 2019
billing data was approximately $g.A million when discounted to
today's dollars using the Company's pre-tax authorized rate of
return of 9.59 percent. This amount closely matches the current
estimated incremental cost of undergrounding. Using 2020 billing
data as a base, the net present value of the 2O-year surcharge
increases to $10.4 million.
To clariff, ldaho Power would prefer to receive a contribution in aid of construction
('C|AC") for the cost of its undergrounding work for the Owl Rock Road Route when the project
is completed. However, because Blaine County was not able to fund a CIAC, ldaho Power agreed
IDAHO POWER COMPANY'S REPLY COMMENTS - 12
to recover the cost of the undergrounding over a 2O-year repayment period through the surcharge
mechanism. Assuming the incremental cost of the undergrounding is $9.8 million, as currently
estimated, ldaho Power will make a $9.8 million capital expenditure for the undergrounding
portion of the Owl Rock Road Route. As noted in Mr. Tatum's testimony, ldaho Power's pr+.tax
authorized rate of return on capital expenditures is 9.59 percent per annum. By applying the 9.59
percentage rate to the recovery of ldaho Powe/s $9.8 million incrementalcapital expenditure for
the Owl Rock Road Route undergrounding, ldaho Power is using the same rate of return it would
use for any other capital expenditure in its regulated utility business in ldaho. ldaho Power has
taken this approach to assure that it recovers its normal costs for Owl Rock Road Route
undergrounding work, and does not "subsidize" the project, potentially at the expense of other
customers.
7. TidwellParaoraph 13
Ms. Tidwell makes severalcomments criticizing the Citizens Advisory Committee ("CAC')
that ldaho Power worked with, beginning in 2007, to prepare the Wood River Electric Plan
('WREP") for the Wood River Valley and surrounding areas, and which included support for a
new redundant transmission line from the Wood River Substation to the Ketchum Substation to
provide urgently needed backup service to the North Valley. ldaho Power's application in the
CPCN Case provided a summary of the important role the CAC played in ldaho Power's electrical
plan for the Wood River Valley:
14.ln2007, a Community Advisory Committee ("CAC") was
convened which developed the Wood River Valley Electrical Plan
("WREP"), which is a comprehensive plan for future transmission
facilities in the Wood River Valley, which includes the North Valley
area. One of the two near-term facility additions identified was a
second 138 kV transmission line between the Wood River and
Ketchum substations. ln 2011, after additional deliberations and
extensive public outreach, the CAC updated the WREP. The CAC
once again recommended that ldaho Power construct the second
138 kV transmission line. The CAC was convened again in 2012to
discuss new information about potential impact to sage grouse
habitat, and the impact to the WREP. Later in 2012, the CAC was
reconvened to provide additional input regarding planned open
IDAHO POWER COMPANY'S REPLY COMMENTS - 13
house events in Hailey, Sun Valley, and Ketchum. High-level cost
estimates were provided, proposed boundaries and approximate
owner costs for a possible local improvement district to fund the
incremental local cost for underground preferences for the
redundant line were included. ln2014, in response to inquiries from
both the City of Ketchum and the Ketchum Energy Advisory
Committee ("KEAC"), the Company invited representatives from
both entities to join the CAC to investigate the possibili$ of any new
alternatives to the proposed redundant line. The "updated" CAC
was convened twice in late 2014. At that time, the updated CAC,
which included two members ftom the KEAC, reaffirmed the need
for a second energy path into the North Valley.
'15. ln addition to the CAC process, ldaho Power has
undertaken additional numerous public involvement activities and
efforts specific to the Wood River Valley. The Company has more
than 100 documented communications; i.e., meetings and letters
with city officials, presentations to committees, open houses,
meetings with residents and subdivisions, etc., regarding
transmission siting in and around the North Valley from 2007 to the
present, in addition to the numerous other informal discussions,
phone calls, and contacts about this matter. Most recently, ldaho
Power took part in several collaborative processes geared towards
exploring the possibility of providing alternative sources of energy
in the North Wood River Valley. The results of this exploration have
shown that the cost of such alternative sources (diesel engine, gas
turbines, and photovoltaic plus battery energy storage systems) are
significantly higher than the cost of the redundant line and provide
less reliability.
The CAC played an essential role in ldaho Powe/s electrical planning process for the
Wood River Valley, and the Company has greatly benefited from public participation in all of its
regional electric plans across southern ldaho, including the WREP
D. Public Comments
Several public comments were received regarding various aspects of the Company's
filing, the necessity for undergrounding, the application of the surcharge to various customer
classes and areas of the county. The Company addresses these concerns above in its response
to Tidwell paragraph 6. The Company is appreciative of public participation in this case and
reiterates its belief that the Owl Rock Road Route and related surcharge as proposed provides a
reasonable compromise that balances the competing interests of the Company's customers in
Blaine County, while also protecting other customers in the Company's service area
IDAHO POWER COMPANY'S REPLY COMMENTS - 14
il. coNcLustoN
ldaho Power is grateful for the level of engagement and comments received in this case.
The Company is appreciative of Staffs thoughtful and detailed evaluation of the petition and
surcharge methodology. The Company supports StafPs findings and its recommendation for
approva! of the Transmission Line modifications and surcharge as proposed. As a result, ldaho
Power respectfully reaffirms its request that the Commission issue an Order: (1) approving the
proposed surcharges, tariff schedule, and Accounting Order as presented in its filing; and (2)
approving the Owl Rock Road Route modifications to the line route previously approved by the
CPCN, Order No. 33872, and (3) that the Commission's findings and directives from the CPCN,
Order No. 33872, as well as the order requested in this case, carries wlth it the express authority
over any action or order of other government agencies or local governments that are in conflict
with such orders of the Commission pursuant to ldaho Code $ 67-6528.
Respectfully submitted this 11th day of January, 2022.
Mzddtt<
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 15
CERTIFICATE OF SERVICE
I HEREBY CERTTFY that on the 11th day of January 2022,lserved a true and
corect copy of the within and foregoing IDAHO POWER COMPANY'S REPLY
COMMENTS upon the following named parties by the method indicated below, and
addressed to the following:
Blaine County Board of County
Commissioners
2016 1st Avenue South, Ste. 300
Hailey, lD 83333
Tim Graves, Chief Deputy Blaine
Coun$ Prosecuting Aftorney's Office
2191st Avenue South, Suite 201
Hailey, ID 83333
Blaine County Land Use Department
c/o Tom Bergin
219 1st Avenue South, Suite 208
Hailey, ID 83333
Ronald Williams
HAWLEY TROXELL ENNIS & HAWLEY
877 West Main Street, Suite 1000
Boise, ldaho 83702
Kiki Leslie A. Tidwell
704 N. River St. #1
Hailey, !D 83333
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[e-mail]
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[e-mail]. id. us
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tberq in@co. bla ine. id. us
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rwilliams@ hawlevtroxell. com
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[e-mail]
IDAHO POWER COMPANY'S REPLY COMMENTS - 16
John R. Hammond, Jr.
Dayne Hardie
ldaho Public Utilities Commission
11331 W. Chinden Blvd.
Bldg.8, Ste.201-A
Boise, lD 83714
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, lD 83701
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davn. [e-mail]
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tom. a [e-mail]
[e-mail]
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 17