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HomeMy WebLinkAbout20230110Barretto Direct_Redacted.pdf BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY’S APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE BOARDMAN TO HEMINGWAY 500-KV TRANSMISSION LINE. ) ) ) ) ) ) ) ) CASE NO. IPC-E-23-01 IDAHO POWER COMPANY DIRECT TESTIMONY OF LINDSAY BARRETTO BARRETTO, DI 1 Idaho Power Company Q. Please state your name and business address. 1 A. My name is Lindsay Barretto. My business 2 address is 1221 West Idaho Street, Boise, Idaho 83702. 3 Q. By whom are you employed and in what capacity? 4 A. I am employed by Idaho Power Company (“Idaho 5 Power” or “Company”) as the 500 kilovolt (“kV”) and Joint 6 Projects Senior Manager. 7 Q. Please describe your educational background. 8 A. I received a Bachelor of Science degree in 9 Civil Engineering from Purdue University, West Lafayette, 10 Indiana in 2005. In 2007, I earned a Master of Science 11 degree in Civil Engineering from Purdue University. I am a 12 registered professional engineer in the state of Idaho. 13 Q. Please describe your work experience with 14 Idaho Power. 15 A. I began my employment with Idaho Power in 2010 16 as an engineer in Power Production’s Civil Engineering 17 department. As an engineer I worked on hydroelectric and 18 hatchery projects and regulatory compliance. In 2015, I 19 moved to Transmission and Distribution Engineering and 20 Construction as a project manager leading power line and 21 substation projects. In 2018, I became an Engineering 22 Leader, responsible for the Stations Engineering and Design 23 department. In 2020, I was promoted to my current 24 position, Senior Manager of 500kV and Joint Projects, where 25 BARRETTO, DI 2 Idaho Power Company my responsibilities include supervision over Idaho Power’s 1 500-kV projects. 2 Q. What is the purpose of your testimony in this 3 proceeding? 4 A. My testimony begins with a description of the 5 Boardman to Hemingway transmission line (“B2H project”) 6 design and the standards and guidelines for which it is 7 constructed and operated. Next, I describe the siting and 8 permitting process that has spanned nearly two decades, 9 including the federal, state, and local permits necessary 10 for construction and operation of the B2H project. 11 Finally, I will discuss the costs associated with the B2H 12 project. 13 Q. Have you prepared any exhibits? 14 A. Yes. Exhibit No. 8 presents a cross-section of 15 a transmission tower. Exhibit No. 9 identifies the federal, 16 state, and local permits needed for construction and 17 operation of the B2H project in both Idaho and Oregon. 18 Exhibit No. 10 represents Idaho Power’s final B2H route 19 choice among the alternatives approved by Oregon’s Energy 20 Facilities Siting Council (“EFSC”). Confidential Exhibit 21 No. 11 includes a summary of the B2H project cost estimates 22 by cost category as well as a comparison of B2H project 23 cost estimates prepared between 2018 and 2022 in support of 24 Integrated Resource Plan (“IRP”) preparations and the 25 BARRETTO, DI 3 Idaho Power Company Company’s request with the Public Utility Commission of 1 Oregon for a Certificate of Public Convenience and 2 Necessity (“CPCN”). 3 I. THE B2H PROJECT DESIGN 4 Q. Please describe the design of the B2H project. 5 A. The B2H project is a 500-kV transmission line 6 between Boardman, Oregon and the Hemingway substation in 7 southwestern Idaho. It consists of approximately 298 miles 8 of electric transmission line, with 274 miles located in 9 Oregon and 24 miles in Idaho. The B2H project will require 10 298 miles of single-circuit 500-kV transmission line, 11 removal of 12 miles of existing 69-kV transmission line, 12 rebuilding of 0.9 miles of a 230-kV transmission line, and 13 rebuilding of 1.1 miles of an existing 138-kV transmission 14 line into a new right-of-way. The B2H project is designed 15 to withstand a wide range of physical conditions and 16 extreme events. Because transmission lines are so vital to 17 the electrical grid, design standards are stringent. B2H 18 will adhere to, and in most cases, exceed, the required 19 codes or standards observed for high voltage transmission 20 line design. This approach to the design, construction, and 21 operation of the B2H project will establish utmost 22 reliability for the life of the transmission line. 23 Q. What are the components of a transmission 24 line? 25 BARRETTO, DI 4 Idaho Power Company A. The basic components of a transmission line 1 are the structures/towers, conductors, insulators, 2 foundations to support the structures, and shield wires to 3 prevent lightning from striking conductors. See Exhibit No. 4 8 to my testimony for a cross-section of a transmission 5 tower. For a single-circuit transmission line, such as B2H, 6 power is transmitted via three phase conductors (a phase 7 can also have multiple conductors, called a bundle 8 configuration). These conductors are typically comprised of 9 a steel core to give the conductor tensile strength and 10 reduce sag and of aluminum outer strands. Aluminum is used 11 because of its high conductivity to weight ratio. 12 Shield wires, typically either steel or aluminum and 13 occasionally including fiber optic cables inside for 14 communication, are the highest wires on the structure. 15 Their main purpose is to protect the phase conductors from 16 a lightning strike. 17 Structures are designed to support the phase 18 conductors and shield wires and keep them safely in the 19 air. For the B2H project, structures will primarily be 20 steel lattice tower structures, which provide an economical 21 means to support large conductors for long spans over long 22 distances.1 The typical structure height for B2H is 23 1 H-frame towers, rather than lattice towers, will be used in certain locations to mitigate potential impacts to visual resources. BARRETTO, DI 5 Idaho Power Company approximately 160 feet tall, but structure height will vary 1 depending on location, with a structure located roughly 2 every 1,400 feet on average. The tower height and span 3 length were optimized to minimize ground impacts and 4 material requirements; taller structures could allow for 5 longer spans (fewer structures on average per mile) but 6 would be costlier due to material requirements. Again, the 7 B2H tower and conductors were engineered to maximize 8 benefits and minimize costs and impacts. 9 Q. Are there guidelines or standards for which 10 the structure of a transmission line is designed? 11 A. Yes. Overhead transmission lines have been in 12 existence for over 100 years, and many codes and 13 regulations govern the design and operation of transmission 14 lines. Safety, reliability, and electrical performance are 15 all incorporated into the design of transmission lines. 16 Several notable standards include the: (1) American 17 Concrete Institute 318—Building Code Requirements for 18 Structural Concrete, (2) American National Standards 19 Institute standards (for material specifications), (3) 20 American Society of Civil Engineers (“ASCE”) Manual No.74—21 Guidelines for Electrical Transmission Line Structural 22 Loading, (4) National Electrical Safety Code (“NESC”), (5) 23 Occupational Safety and Health Administration 1910.269 24 April 11, 2014 (for worker safety requirements), and (6) 25 BARRETTO, DI 6 Idaho Power Company National Fire Protection Association 780—Guide for 1 Improving the Lightning Performance of Transmission Lines. 2 NESC provides for minimum guidelines and industry standards 3 for safeguarding persons from hazards arising from the 4 construction, maintenance, and operation of electric supply 5 and communication lines and equipment. The B2H project will 6 be designed, constructed, and operated at standards that 7 meet, and in most cases exceed, the provisions of NESC. 8 Q. Why is Idaho Power designing and constructing 9 the B2H project to exceed NESC provisions? 10 A. Physical loads induced onto transmission 11 structures and foundations supporting the phase conductors 12 and shield wires for the B2H project are derived from three 13 phenomena: wind, ice, and tension. Under certain 14 conditions, ice can build up on phase conductors and shield 15 wires of transmission lines. When transverse wind loading 16 is also applied to these iced conductors, it can produce 17 structural loading on towers and foundations far greater 18 than normal operating conditions produce. Design weather 19 cases for the B2H project exceed the requirements in the 20 NESC. As an example, for a high wind case, NESC recommends 21 90 miles per hour (mph) winds. The criteria proposed for 22 the B2H project is 100 mph wind on the conductors and 120 23 mph wind on the structures. There are multiple loading 24 conditions that will be incorporated into the design of the 25 BARRETTO, DI 7 Idaho Power Company B2H project, including unbalanced longitudinal loads, 1 differential ice loads, broken phase conductors, broken 2 sub-phase conductors, heavy ice loads, extreme wind loads, 3 extreme ice and wind loads, construction loads, and full 4 dead-end structure loads. 5 Q. What is the design of the transmission line 6 foundation? 7 A. The 500-kV single-circuit lattice steel 8 structures require a foundation for each leg of the 9 structure. The foundation diameter and depth will be 10 determined during final design and are dependent on the 11 type of soil or rock present. The foundations will be 12 designed to comply with the allowable bearing and shear 13 strengths of the soil where placed. Soil borings will be 14 taken at key locations along the project route, and 15 subsequent soil reports and investigations will govern 16 specific foundation designs as appropriate. 17 Q. Are there guidelines or standards for design 18 of transmission line foundations? 19 A. Yes. The 2017 NESC Rule 250A4 observes the 20 structure capacity obtained by designing for NESC wind and 21 ice loads at the specified strength requirements is 22 sufficient to resist earthquake ground motions. 23 Additionally, ASCE Manual No. 74 states transmission 24 structures need not be designed for ground-induced 25 BARRETTO, DI 8 Idaho Power Company vibrations caused by earthquake motion. Historically, 1 transmission structures have performed well under 2 earthquake events,2 and transmission structure loadings 3 caused by wind/ice combinations and broken wire forces 4 exceed earthquake loads. It is common industry practice to 5 design transmission line structures to withstand wind and 6 ice loads that are equal to, or greater than, these NESC 7 requirements. 8 Q. How does the potential for lightning impact 9 the design? 10 A. The B2H project is in an area that 11 historically experiences 20 lightning storm days per year,3 12 which is relatively low compared to other parts of the 13 United States. The transmission line will be designed to 14 not exceed a lightning outage rate of one per 100 miles per 15 year. This will be accomplished by using proper shield wire 16 placement and structure/shield wire grounding to adequately 17 dissipate a lightning strike on the shield wires or 18 structures if it were to occur. The electrical grounding 19 requirements for the project will be determined by 20 performing ground resistance testing throughout the project 21 2 Risk Assessment of Transmission System under Earthquake Loading. J.M. Eidinger, and L. Kemper, Jr. Electrical Transmission and Substation Structures 2012, Pg. 183-192, ASCE 2013; see also Earthquake Resistant Construction of Electric Transmission and Telecommunication Facilities Serving the Federal Government Report. Felix Y. Yokel. Federal Emergency Management Agency (FEMA). September 1990. 3 USDA RUS Bulletin 1751-801. BARRETTO, DI 9 Idaho Power Company alignment, and by designing adequately sized counterpoise 1 or using driven ground rods with grounding attachments to 2 the steel rebar cages within the caisson foundations as 3 appropriate. 4 Q. What measures have been taken with respect to 5 the B2H project design for earthquakes? 6 A. Experience has demonstrated that high-voltage 7 transmission lines are very resistant to ground-motion 8 forces caused by earthquake, so much so that national 9 standards do not require these forces be directly 10 considered in the design. However, secondary hazards can 11 affect a transmission line, such as landslides, 12 liquefaction, and lateral spreading. The design process 13 considers these geologic hazards using multiple information 14 streams throughout the siting and design process. For the 15 final route, Idaho Power evaluated geologic hazards using 16 available geographic information system data, such as fault 17 lines, areas of unstable and/or steep soils, mapped and 18 potential landslide areas, etc. Towers located within 19 potential geologic hazard areas are investigated further to 20 determine risk. Additional analysis may include field 21 reconnaissance to gauge the stability of the area and 22 subsurface investigation to determine the soil strata and 23 depth of hazard. 24 Q. Did the Company identify any geologic hazards 25 BARRETTO, DI 10 Idaho Power Company that would be of risk to the structure? 1 A. At this time, no high-risk geologic hazard 2 areas have been identified. If, during the process of final 3 design, an area is found to be high-risk, the first option 4 would be to microsite, route around, or span over the 5 hazard. If avoidance is not feasible, the design team would 6 seek to stabilize the hazard. Engineering options for 7 stabilization include designing an array of sacrificial 8 foundations above the tower foundation to anchor the soil 9 or improving the subsurface soils by injecting grout or 10 outside aggregates into the ground. If the geotechnical 11 investigation determines the problematic soils are 12 relatively shallow, the tower foundations can be designed 13 to pass through the weaker soils and embed into competent 14 soils. 15 Q. Please describe Idaho Power’s plans to reduce 16 risks associated with wildfire during operation of the B2H 17 project. 18 A. Idaho Power has developed a Wildfire 19 Mitigation Plan (“WMP”).4 This plan details how the Company 20 uses situational awareness of wildfire and weather 21 conditions to change the way the system is operated. It 22 4 2022 Wildfire Mitigation Plan (idahopower.com), see also In the Matter of Idaho Power Company’s Application for Review of the Company’s Current Wildfire Mitigation Plan and Authorization to Defer Newly Identified Incremental Wildfire Mitigation Costs (Case No. IPC-E-22-27). BARRETTO, DI 11 Idaho Power Company also includes best practices that internal and contract 1 crews follow for construction and maintenance activities 2 during wildfire season, vegetation management practices, 3 and transmission system and distribution system hardening 4 efforts. B2H has been included in this analysis as part of 5 the planning process. The wildfire risk along the B2H 6 project route was assessed as part of the plan. This plan 7 will be reviewed annually and updated with new information 8 and lessons learned as required. 9 Q. Will the B2H project remain operational in the 10 event of a wildfire? 11 A. The transmission line steel structures are 12 constructed of non-flammable materials, so wildfires do not 13 pose a physical threat to the transmission line itself. 14 However, heavy smoke from wildfires in the immediate area 15 of the transmission line can cause flashover/arcing between 16 the phase conductors and electrically grounded components. 17 Standard operation is to de-energize transmission lines 18 when fire is present in the immediate area of the line. 19 Transmission lines generally remain in-service when smoke 20 is present from wildfires not in the immediate vicinity of 21 the transmission line. When compared to other resource 22 alternatives, the B2H project may be more resilient to 23 smoke. For example, the recent forest fire events in the 24 Pacific Northwest caused smoke along the proposed B2H 25 BARRETTO, DI 12 Idaho Power Company corridor and in the Pacific Northwest in general. While 1 generation from solar photovoltaic would likely operate at 2 a much-reduced capacity, the B2H project would likely still 3 operate so long as the fires are not in the immediate area. 4 Q. Are there any other hazards the B2H project 5 design must take into account? 6 A. As I mentioned earlier, the B2H project is 7 designed to withstand extreme wind loading combined with 8 ice loading. With respect to landslides, Idaho Power 9 avoided steep, unstable slopes through the siting and 10 design process, especially where evidence of past 11 landslides is evident. During the preliminary construction 12 phase, geotechnical surveys and ground surveys (light 13 detection and ranging surveys) help verify potentially 14 hazardous conditions. If a potentially hazardous area 15 cannot be avoided, the design process will seek to 16 stabilize the area. Finally, identification and avoidance 17 of flood zones was incorporated into the siting process and 18 will be further incorporated into the design process. 19 Foundations and structures will be designed to withstand 20 anticipated flood conditions. 21 Q. Was any consideration made in the event of a 22 direct physical attack? 23 A. Yes. A direct physical attack on the B2H 24 transmission line will remove the line’s ability to deliver 25 BARRETTO, DI 13 Idaho Power Company power to customers. In the case of a direct attack, B2H is 1 fundamentally no different than any other supply-side 2 resource under a direct physical attack. However, because 3 the B2H project is connected to the transmission grid, a 4 direct physical attack on any specific generation site in 5 the Pacific Northwest or Mountain West region will not 6 limit the B2H project’s ability to deliver power from other 7 generation in the region. In this context, the B2H project 8 provides additional ability for generation resources to 9 serve load if a physical attack were to occur on a specific 10 generation resource or location within the region and 11 therefore increases the resiliency of the electric grid as 12 a whole. 13 If a direct physical attack were to occur on the B2H 14 transmission line and force the line out of service, the 15 rest of the grid would adjust to account for the loss of 16 the line. Per the Western Electricity Coordinating Council 17 facility rating process, the B2H capacity rating is such 18 that an outage of the B2H line would not overload any other 19 system element beyond equipment emergency ratings. Idaho 20 Power also keeps a supply of emergency transmission towers 21 that can be quickly deployed to replace a damaged tower 22 allowing the transmission line to be quickly returned to 23 service. Transmission lines add to the resiliency of the 24 grid by providing additional paths for electricity should 25 BARRETTO, DI 14 Idaho Power Company one or more generation resources or transmission lines 1 experience a catastrophic event. 2 Q. Is there any incremental value the B2H project 3 may provide in the event of emergency conditions? 4 A. During non-emergency conditions, the transfer 5 capability between the Pacific Northwest and Idaho will be 6 limited by real-time-contingency-analysis to ensure a 7 single transmission system element outage does not result 8 in overloading any remaining element above its emergency 9 rating (i.e. loss of the B2H project does not result in a 10 remaining system element overloaded above its emergency 11 rating). Per North American Electric Reliability 12 Corporation (“NERC”) requirement TPL-001-4, the system must 13 be designed to accommodate single contingency element 14 losses without using load tripping as mitigation. However, 15 during emergency conditions, transfers across the B2H 16 project could be increased above the normal rating by 17 implementing a remedial action scheme, also pursuant to 18 NERC TPL-001-4 for emergency conditions starting from an 19 outage scenario. 20 II. SITING AND PERMITTING 21 Q. When did siting and permitting of the B2H 22 project begin? 23 A. In 2007, Idaho Power filed a Preliminary Draft 24 Application for Transportation and Utility Systems and 25 BARRETTO, DI 15 Idaho Power Company Facilities on Federal Lands and began scoping routes. The 1 following year, in 2008, the Company submitted application 2 materials to the Bureau of Land Management (“BLM”) as the 3 lead agency for the federal National Environmental Policy 4 Act (“NEPA”) review and a Notice of Intent to the Oregon 5 Energy Facility Siting Council (“EFSC” or “Council”). The 6 NEPA and EFSC processes are separate and distinct 7 permitting processes and not necessarily designed to work 8 simultaneously. At a high level, the NEPA process requires 9 federal agencies take a “hard look” at the environmental 10 consequences of their actions along with reasonable 11 alternatives, but NEPA does not mandate a particular 12 result. The comparative analysis is conducted at a 13 “desktop” level. Information is brought into the process on 14 a phased approach. A more detailed analysis must be 15 conducted on the final route prior to construction, which 16 generally occurs once final design is complete. On the 17 other hand, the Oregon EFSC process is a standards-based 18 process based on a fixed site boundary. For a linear 19 facility, like a transmission line, the process requires 20 the transmission line boundary to be established (one or 21 more routes selected) and fully evaluated to determine if 22 the project meets established standards. 23 Q. What occurred when the application was 24 submitted to the BLM? 25 BARRETTO, DI 16 Idaho Power Company A. The BLM responded with a Notice of Intent to 1 prepare an Environmental Impact Statement (“EIS”), 2 officially initiating the BLM-led federal NEPA process. It 3 was at this time that Idaho Power embarked on a more 4 extensive public outreach program to determine the 5 transmission line route. 6 Q. Did the Company involve public participation 7 when determining the route for the B2H project? 8 A. Yes. In 2009, Idaho Power paused the NEPA and 9 EFSC activities to work with community members throughout 10 the siting area to identify a proposed route that would be 11 acceptable to both the Company and the public. The year-12 long community advisory process (“CAP”) had four objectives 13 and steps: (1) identify community issues and concerns, (2) 14 develop a range of possible routes that address community 15 issues and concerns, (3) recommend proposed and alternate 16 routes, (4) follow through with communities during the 17 federal and state review processes. Through the CAP, Idaho 18 Power hosted 27 Project Advisory Team meetings, 15 public 19 meetings, and 7 special topic meetings. In all, nearly 20 1,000 people were involved in the CAP, either through 21 Project Advisory Team activities or public meetings. 22 Q. Was a proposed route selected through the CAP 23 process? 24 A. Yes. Forty-nine routes and/or route segments 25 BARRETTO, DI 17 Idaho Power Company were considered through the CAP and ultimately the route 1 recommendation from the CAP was the route Idaho Power 2 brought into the NEPA process as the proponent-recommended 3 route, submitted in 2010. 4 Q. What occurred following conclusion of the CAP? 5 A. With a final route recommendation developed 6 through the CAP, Idaho Power resubmitted the proposed route 7 to the BLM and published its B2H Siting Study. At this 8 point, the Company also filed a new Notice of Intent with 9 EFSC. 10 Q. Was this the end of public involvement in the 11 final selection of the B2H project’s route? 12 A. No, public involvement and outreach continued 13 for years. The NEPA process, which the BLM re-initiated 14 following the Company’s resubmittal of a proposed route, 15 included additional opportunities for public comment at 16 major milestones, and Idaho Power worked with landowners 17 and communities along the way. Throughout this process, 18 Idaho Power worked with landowners, stakeholders, and 19 jurisdictional leaders on route refinements and to balance 20 environmental impacts with impacts to farmers and ranchers. 21 For example, Idaho Power met with the original “Stop Idaho 22 Power” group in Malheur County to help the group 23 effectively comment and seek change from the BLM when the 24 Draft EIS indicated a preference for a route across Stop 25 BARRETTO, DI 18 Idaho Power Company Idaho Power stakeholders’ lands. The BLM’s decision was 1 modified, and the route moved away from an area of highly 2 valued agricultural lands in the Final EIS almost two years 3 later. 4 Idaho Power also worked with landowners in the Baker 5 Valley, near the National Historic Oregon Trail 6 Interpretive Center (“NHOTIC”), to move an alternative 7 route along fence lines to minimize impacts to irrigated 8 farmland, where practicable. This change was submitted by 9 the landowners and included in the BLM’s Final EIS and 10 ultimately the Record of Decision. Another change in Baker 11 County was in the Burnt River Canyon and Durkee area, where 12 Idaho Power worked with the BLM and affected landowners to 13 find a more suitable route than what was initially 14 identified as the preferred route in the Draft EIS. Idaho 15 Power has worked with landowners and local jurisdictional 16 leaders to microsite in these areas to minimize impacts. 17 Finally, in Union County Idaho Power worked with 18 local jurisdictional leaders, stakeholder groups, such as 19 the Glass Hill Coalition and some members of Stop B2H 20 (prior to that group’s formation), to identify new route 21 opportunities. The Union County B2H Advisory Committee 22 agreed to submit a route proposal to the BLM that followed 23 existing high-voltage transmission lines, which was later 24 identified as the Mill Creek Alternative. In that same 25 BARRETTO, DI 19 Idaho Power Company area, Idaho Power proposed the Morgan Lake Alternative as 1 an alternative to the Mill Creek Route, providing a route 2 that was farther from and not visible from the City of La 3 Grande. 4 Q. What was the status of the EFSC application at 5 this time? 6 A. In 2012, concurrent with the BLM NEPA process, 7 the Oregon Department of Energy (“ODOE”) conducted informal 8 meetings, solicited comments, and issued a Project Order 9 outlining the issues and regulations Idaho Power must 10 address in its Application for Site Certificate (“ASC”). 11 Also, due to the route modifications and refinements 12 submitted to the BLM, the Company issued a Siting Study 13 Supplement, and began conducting field surveys for the ASC. 14 Idaho Power submitted to ODOE its preliminary ASC in 2013, 15 which included a request that the site certificate include 16 and govern the local land use approvals related to siting. 17 Q. Had the BLM-led NEPA process concluded at this 18 point? 19 A. No. In 2013, the BLM released the preliminary 20 preferred route alternatives and began preparing their 21 Draft EIS, which was issued on December 19, 2014, 22 identifying an Agency Preferred Alternative. 23 Q. Was the route proposed through the CAP the 24 final route selected by the BLM? 25 BARRETTO, DI 20 Idaho Power Company A. No. The route preferences of Idaho Power and 1 the local communities are not always reflected in the BLM’s 2 Agency Preferred route. For example, Idaho Power had worked 3 in the Baker County area to propose a route on the backside 4 of the NHOTIC to minimize visual impacts, and in the Brogan 5 area to avoid landowner impacts. However, both route 6 variations went through priority sage grouse habitat and 7 were not adopted in BLM’s Agency Preferred route. However, 8 the Company worked with Umatilla County, local 9 jurisdictional leaders, and landowners to identify a new 10 route through the entire county, essentially moving the 11 line further south and away from residences, ranches, and 12 certain agriculture. This southern route variation through 13 Umatilla County was later included as part of the BLM’s 14 final Agency Preferred route. 15 Q. What occurred following issuance of the Draft 16 EIS? 17 A. The BLM’s issuance of the Draft EIS kicked off 18 the opening of a 90-day comment period. The BLM hosted 19 open houses for the public to learn about the Draft EIS, 20 route alternatives, and environmental analysis. On November 21 22, 2016, the BLM completed its NEPA process, issuing its 22 Final EIS. The preferred route was incorporated into the 23 EFSC application and a routing solution on Navy-owned land 24 for an easement on the Naval Weapons System Training 25 BARRETTO, DI 21 Idaho Power Company Facility in Boardman, Oregon. Field surveys necessary for 1 the EFSC application continued to be conducted. In 2017, 2 the Company submitted an Amended Preliminary ASC to ODOE. 3 On November 17, 2017, the BLM released its record of 4 decision for the B2H project, authorizing the BLM to grant 5 a right-of-way to Idaho Power for the construction, 6 operation, and maintenance of the B2H project on BLM-7 administered land. The right-of-way was granted on January 8 9, 2018. 9 Q. Were any additional decisions required with 10 respect to rights-of-way for the B2H project? 11 A. Yes. The BLM’s record of decision triggered 12 United States Forest Service (“USFS”) and Navy decision 13 activities. The USFS and Navy issued their own separate 14 decisions regarding rights-of-way across lands under their 15 jurisdictions on November 13, 2018, and September 26, 2019, 16 respectively. With issuance of the Navy record-of-17 decision, after nearly 10 years, the B2H project had 18 secured all federal records of decision. 19 Q. Was the final B2H project route proposed by 20 the Company in the EFSC ASC the route proposed by the BLM? 21 A. No. The route Idaho Power submitted to the 22 EFSC as part of the ASC is very similar to the BLM’s Agency 23 Preferred route. When the ASC was finalized, which was 24 prior to issuance of the Final EIS, Idaho Power included 25 BARRETTO, DI 22 Idaho Power Company two alternative route segments in the La Grande area, 1 called the Morgan Lake Alternative and the Mill Creek 2 Alternative/Proposed Route. The BLM’s Agency Preferred 3 route in that area was similar to a prior route concept 4 that was called the Glass Hill Alternative. Additionally, 5 the EFSC application included alternative route segments at 6 the northern end of the B2H project, near the Boardman 7 Bombing Range, and toward the southern end of the of the 8 B2H project in Malheur County near the Double Mountain 9 Wilderness Characteristic Unit. 10 Q. What is the current status of the Council’s 11 review of the Company’s ASC? 12 A. In July 2020, ODOE issued its Proposed Order, 13 proposing approval of the B2H project subject to certain 14 conditions. However, certain members of the public objected 15 to aspects of the proposed order, and EFSC initiated a 16 contested case hearing process to consider the issues that 17 those members of the public raised. The contested case 18 spanned nearly two years and included exchange of 19 discovery, live depositions, submission of written 20 testimony, live cross-examination hearings, and extensive 21 briefing. On May 31, 2022, at the conclusion of the 22 contested case, the hearing officer issued a Proposed 23 Contested Case Order, proposing approval of the B2H project 24 BARRETTO, DI 23 Idaho Power Company subject to certain conditions.5 The Council held a three-1 day hearing to consider the parties’ exceptions to the 2 Proposed Contested Case Order, and provided direction to 3 ODOE regarding modifications to the Proposed Order and the 4 Proposed Contested Case Order. ODOE implemented the 5 Council’s direction and issued the draft Final Order on 6 September 16, 2022, and on September 27, 2022, EFSC made 7 its final decision in a unanimous (6-0) vote to approve the 8 B2H project subject to certain conditions. 9 Q. Has the EFSC issued their Final Order and Site 10 Certificate? 11 A. Yes. On October 6, 2022, EFSC executed their 12 Final Order and Site Certificate for the B2H project.6 13 Q. Has the Final Order been appealed? 14 A. Yes. In accordance with the statutory time 15 limitation for appeal of the final order, three parties 16 timely filed appeals to the Supreme Court of Oregon in 17 connection with EFSC’s Final Order. However, in accordance 18 with Oregon Revised Statute (“ORS”) 469.403(4), the filing 19 of a petition for judicial review does not stay the 20 Council’s Final Order—and no party has requested stay—and 21 5 See Administrative Law Judge’s Proposed Contested Case Order, page 296 of 337 (May 31, 2022) (I propose the Oregon Department of Energy, Energy Facility Siting Council, issue a Final Order granting the requested site certificate consistent with the Department’s Proposed Order dated July 2, 2020, including the recommended site certificate conditions, and incorporating the following amendments to recommended conditions: . . . .). 6 See Final Order (Sept. 27, 2022) (available at: https://www.oregon.gov/energy/facilities- safety/facilities/Facilities%20library/2022-09-27-Final-Order-on-ASC.pdf BARRETTO, DI 24 Idaho Power Company thus, the EFSC Final Order and EFSC Site Certificate remain 1 in effect pending judicial review. Accordingly, Idaho Power 2 may begin construction in areas where it has site control 3 and where all pre-construction conditions have been met, 4 notwithstanding the appeal. Idaho Power filed Answering 5 Briefs on January 3, 2023, and Oral Argument is scheduled 6 for January 18, 2023. Pursuant to 469.403(6), the Oregon 7 Supreme Court must render a decision within six months of 8 the petitions for review, or in this case, on or before 9 June 6, 2023. 10 Q. What additional permits and land use approvals 11 are necessary for siting the B2H project? 12 A. Exhibit No. 9 to my testimony identifies the 13 federal, state, and local permits needed for construction 14 and operation of the B2H project in both Idaho and Oregon. 15 The permits and approvals beyond those I have discussed are 16 in various stages of their respective application and 17 approval processes, the status of which is also presented 18 in Exhibit No. 9. The Final Order and Site Certificate 19 include the land use approvals (and related conditions) for 20 the B2H project, and in accordance with Oregon Revised 21 Statute 469.401(3), following issuance of the site 22 certificate, the state and local agencies in Oregon will 23 issue the permits and land use approvals governed by the 24 site certificate without further hearings or other 25 BARRETTO, DI 25 Idaho Power Company proceedings. 1 Q. You indicated the EFSC application included 2 alternative route segments for portions of the B2H project. 3 Has the Company determined a final route for the B2H 4 project? 5 A. Yes. Exhibit No. 10 to my testimony 6 represents Idaho Power’s final route choice among the 7 alternatives approved by EFSC, which includes the Morgan 8 Lake Alternative and the West of Bombing Range Alternative 9 1 routes. 10 Q. How did Idaho Power determine the final route 11 among the approved alternative options? 12 A. Idaho Power initially proposed the Mill Creek 13 Route in response to the request by Union County that the 14 B2H project be routed parallel to the existing 230-kV 15 transmission line. In that same area, Idaho Power proposed 16 the Morgan Lake Alternative as an alternative to the Mill 17 Creek Route, providing a route that was farther from and 18 not visible from the City of La Grande. Based on feedback 19 Idaho Power received from the local community and given 20 EFSC approved both routes, Idaho Power has decided to 21 develop the Morgan Lake Alternative and not the Mill Creek 22 Route. 23 III. B2H PROJECT ROUTE IMPACT EVALUATIONS 24 Q. Did Idaho Power evaluate the potential impact 25 BARRETTO, DI 26 Idaho Power Company of the B2H project on topography, geology, stream 1 crossings, or other similar conditions? 2 A. Yes. With respect to hydrologic systems, the 3 Company anticipates the impact will be minimal. For 4 example, any temporary impacts to regulated waters will be 5 mitigated by restoring the sites to existing conditions, 6 and the total amount of permanent impacts will be less than 7 0.5 acres.7 To mitigate those impacts, Idaho Power has 8 acquired the rights to develop a wetland and stream 9 restoration project along Catherine Creek, a tributary to 10 the Grande Ronde River.8 11 The Company does not anticipate that construction-12 related blasting activity will impact landowners’ springs, 13 wells, or other water sources. However, to address any 14 concerns the landowners may have regarding the same, Idaho 15 Power will test water sources if requested, as memorialized 16 in the site certificate condition, Soil Protection 17 Condition 4.b.9 18 Geological hazards are addressed in the ASC as well. 19 The B2H project will be designed in accordance with 20 multiple applicable engineering and building standards, 21 which address, directly or indirectly, hardness of rock and 22 7 As detailed in Exhibit J (Waters of the State) to Idaho Power’s ASC, page J-16 (Sept. 28, 2018). 8 As detailed in Exhibit J (Waters of the State) to Idaho Power’s ASC, page J-17 to J-18 (Sept. 28, 2018). 9 As detailed in Site Certificate at 24 (Sept. 27, 2022). BARRETTO, DI 27 Idaho Power Company other geological considerations.10 Additionally, Idaho Power 1 is required to prepare, in consultation with the Oregon 2 Department of Geology and Mineral Industries, a geologic 3 report that addresses the suitability of the site for the 4 B2H project and any mitigation measures.11 While the final 5 mitigation measures will be refined prior to construction 6 based on site-specific geological testing, generally, those 7 measures will include modifications to tower locations, 8 design changes to structure foundations, soil amendments, 9 or tower design modifications. 10 Q. Were any mitigation measures implemented for 11 scenic or recreational resources? 12 A. Yes. Per an agreement with the City of La 13 Grande, the Company will provide funding to the city for 14 recreational improvements at Morgan Lake Park.12 15 Additionally, Idaho Power will construct the B2H project 16 segment near Morgan Lake Park using shorter, H-frame towers 17 with a weathered steel finish to reduce visual impacts to 18 the park.13 Similarly, in the vicinity of the NHOTIC and the 19 Birch Creek Area of Critical Environmental Concern, Idaho 20 Power will construct the B2H project using shorter, H-frame 21 10 See Exhibit H (Geological Hazards and Soil Stability) to the Company’s ASC, page H-21 (Sept. 28, 2018). 11 See Exhibit H (Geological Hazards and Soil Stability) to Idaho Power’s ASC, pages H-4 to H-5, and Engineering Geology and Seismic Hazards Supplement, Attachment H-1 to Idaho Power’s ASC. 12 See EFSC’s Final Order at 277-78 (Sept. 27, 2022) (available at 2022-09-27- Final-Order-on-ASC.pdf (oregon.gov)) (last visited Sept. 29, 2022). 13 Id. at 557. BARRETTO, DI 28 Idaho Power Company towers instead of lattice towers to reduce the visual 1 impacts to these resources.14 2 Q. Were potential cultural, environmental or 3 agricultural impacts evaluated? 4 A. Yes. To receive a site certificate from EFSC, 5 the B2H project must undergo a thorough review and meet the 6 Council's siting standards. Those standards address issues 7 such as soil protection, land use, protected areas, fish 8 and wildlife habitat, threatened and endangered species, 9 scenic resources, historic, cultural, and archaeological 10 resource, recreation opportunities, public services, waste 11 minimization, and others.15 Idaho Power addressed the EFSC 12 standards in the Company’s ASC, where Idaho Power analyzes 13 the B2H project’s potential impacts on those resources and 14 describes the measures the Company will employ to avoid, 15 minimize, or mitigate the potential impacts. Some of the 16 potential impacts that were analyzed and the commitments 17 the Company has made to address those potential impacts 18 include: 19 Historic, cultural, and archaeological resources: 20 Idaho Power conducted extensive records research, 21 literature review, and field surveys to inventory the 22 historic, cultural, and archaeological resources that 23 14 Id. at 451. 15 See OAR Chapter 345, Division 22. BARRETTO, DI 29 Idaho Power Company potentially will be impacted by the B2H project.16 For 1 identified resources, Idaho Power will implement measures 2 to avoid or minimize adverse impacts, including relocation 3 of structures through the design process, realignment of 4 the route, relocation of temporary workspace, or changes in 5 the construction and/or operational design. Where impacts 6 are unavoidable, Idaho Power will implement mitigation 7 actions set forth in a Historic Properties Management Plan, 8 which was developed in coordination with various 9 governmental agencies, including environmental training, 10 data recovery, analysis, documentation, curation, resource-11 specific treatments, restoration, public signage, 12 publication, and interpretive planning.17 13 Fish and wildlife habitat: Idaho Power catalogued 14 the various types of fish and wildlife habitat potentially 15 impacted by the B2H project through desktop analysis and 16 ground surveys.18 To avoid and minimize impacts to fish and 17 wildlife habitat, the Company will implement seasonal work 18 restrictions, map and flag sensitive resources, and 19 implement various other measures set forth in the Company’s 20 Reclamation and Revegetation Plan, Vegetation Management 21 16 See Exhibit S (Historic, Cultural, and Archeological Resources) to Idaho Power’s ASC, pages S-21 through S-28. 17 See Historic Properties Management Plan, Attachment S-9 to the EFSC Final Order (Sept. 27, 2022). 18 See Exhibit P1 (Fish and Wildlife Habitat) to Idaho Power’s ASC, pages P1-21 through P1-31. BARRETTO, DI 30 Idaho Power Company Plan, and Noxious Weed Plan.19 Unavoidable impacts will be 1 addressed through compensatory mitigation, as outlined in 2 the Fish and Wildlife Habitat Mitigation Plan.20 3 In addition, to avoid and minimize impacts to avian 4 species during construction, Idaho Power will limit 5 construction activities to time periods outside of the 6 primary migratory bird nesting season of April 1 to July 7 15, unless the Company conducts surveys immediately prior 8 to such activities to identify avian nests to avoid, as 9 memorialized in the proposed EFSC site certificate 10 conditions, Fish and Wildlife Condition 13, Fish and 11 Wildlife Condition 14, and Fish and Wildlife Condition 20.21 12 During operations, Idaho Power will implement its Avian 13 Protection Plan, which includes mitigation measures to be 14 taken if avian mortalities are discovered along the 15 transmission line and modifications to the line that can be 16 made if elevated mortalities of avian species are 17 discovered.22 With respect to bat species, Idaho Power 18 avoided and minimized impacts by siting the B2H project to 19 avoid mines, caves, and known bat hibernacula.23 20 19 See Exhibit P1 (Fish and Wildlife Habitat) to Idaho Power’s ASC, pages P1-86 through P1-90; Reclamation and Revegetation Plan, Attachment P1-3 to EFSC’s Final Order; Vegetation Management Plan, Attachment P1-4 to EFSC’s Final Order; and Noxious Weed Plan, Attachment P1-5 to EFSC’s Final Order. 20 See Fish and Wildlife Mitigation Plan, Attachment P1-6 to EFSC’s Final Order. 21 EFSC Final Order at 375-76, 399. 22 See Avian Protection Plan at 15 included as Attachment P1-9 to EFSC’s Final Order. 23 See Exhibit P1 (Fish and Wildlife Habitat) to Idaho Power’s ASC, page P1-70 (Sept. 28, 2018). BARRETTO, DI 31 Idaho Power Company Additionally, if previously unidentified hibernacula are 1 located, Idaho Power will develop additional avoidance, 2 minimization, and mitigation measures in consultation with 3 the Oregon Department of Fish and Wildlife, as set forth in 4 the proposed site certificate condition identified as Fish 5 and Wildlife Condition 12.24 6 Land use: Idaho Power analyzed, and demonstrated 7 compliance with, the affected cities and counties’ 8 comprehensive plans and development codes.25 The Company 9 addressed potential impacts to agricultural operations in 10 particular in the Company’s Agricultural Lands Assessment.26 11 In that document, Idaho Power includes various measures the 12 Company will undertake to avoid, minimize, and mitigate 13 impacts to agricultural lands and operations, including 14 locating towers outside cultivated fields where feasible, 15 scheduling construction activities around agricultural 16 operations, avoiding damage to drainage tiles, restoring 17 compacted soils, noxious weed control, and other measures.27 18 Idaho Power has made a tremendous effort to design 19 the route of the transmission line to avoid irrigated areas 20 and has sited towers along agricultural field boundaries 21 where feasible. Of the approximately 1,461 transmission 22 24 EFSC Final Order at 374. 25 See Exhibit K (Land Use) to Idaho Power’s ASC. 26 See Agricultural Lands Assessment, Attachment K-1 to EFSC’s Final Order. 27 Id. at 37-42. BARRETTO, DI 32 Idaho Power Company towers along the proposed route, only 26 are proposed to be 1 located within an irrigated portion of an agricultural 2 field, and Idaho Power may be able to further reduce this 3 total number through micrositing, which provides the 4 flexibility to marginally shift the transmission line 5 within a 500-ft wide site boundary.28 The Company is 6 committed to working with each landowner to try to minimize 7 impacts to farming operations where feasible for the 8 construction of the line, and will move structures out of 9 cultivated fields where practical. 10 Q. Were any statewide or local economic impacts 11 associated with construction of the B2H project evaluated? 12 A. Yes. The B2H project will have positive 13 economic impacts for eastern Oregon communities include 14 construction jobs, economic support associated with 15 infrastructure development (e.g., lodging and food), and 16 increased annual tax benefits to each county for project-17 specific property tax dollars, totaling an estimated $5.8 18 million.29 In addition, Idaho Power anticipates the project 19 will add about 500 construction jobs, which will provide a 20 temporary increase in spending at local businesses. 21 As explained in Company witness Mr. Ellsworth’s 22 testimony, when energized, the B2H project will benefit 23 28 Id. at 26. 29 See Idaho Power’s 2021 IRP Appendix D. BARRETTO, DI 33 Idaho Power Company local economies by providing cost-effective energy, adding 1 1,050 megawatts of transmission connectivity between the 2 Bonneville Power Administration (“BPA”) and Idaho Power 3 systems. Currently, the transmission connections between 4 BPA and Idaho Power are fully committed for existing 5 customer commitments. Along the B2H project route, Idaho 6 Power currently serves customers in Idaho’s Owyhee County 7 and in Oregon’s Malheur County and portions of Baker 8 County. PacifiCorp, through Pacific Power, serves portions 9 of Umatilla County. BPA provides transmission service to 10 local cooperatives in the remainder of the project area in 11 Morrow, Umatilla, Union, and Baker counties. Cost-effective 12 energy also provides economic development opportunities in 13 these areas. Finally, additional transmission capacity can 14 create opportunities for new energy resources, which can 15 add to the county tax base and create new jobs. 16 Q. Are there any negative economic impacts that 17 may occur with construction of the B2H project? 18 A. The Company does not anticipate the B2H 19 project will have any negative economic impacts at a 20 statewide or regional level. However, Idaho Power 21 recognizes the B2H project may have negative economic 22 impacts on individual landowners in the form of removing 23 timber or agricultural land from production; interference 24 with timber, agricultural, or other land uses during 25 BARRETTO, DI 34 Idaho Power Company construction; and impacts on land values. To address those 1 concerns, the Company has developed management plans 2 containing best practices to avoid, minimize, and mitigate 3 such impacts. For example, the Company’s Right-of-Way 4 Clearing Assessment includes a multitude of actions 5 designed to minimize and mitigate impacts to forested lands 6 and forestry operations, including logging best management 7 practices, fire protection practices, road maintenance and 8 improvements, and erosion controls.30 Additionally, Idaho 9 Power’s Agricultural Lands Assessment includes numerous 10 minimization and mitigation efforts to address impacts to 11 agricultural lands and operations, including tower 12 placement modifications, coordinated construction 13 scheduling, coordinated helicopter options, maintenance and 14 repair of drainage tiles, remediating soil compaction, 15 noxious weed control, topsoil separation and storage, dust 16 control, soil erosion protection, addressing inducted 17 voltage, livestock control measures, and protections for 18 organic crops.31 Finally, Idaho Power will compensate 19 impacted landowners where the B2H project will be located 20 for the use of their land through utility easement 21 negotiations. 22 30 See the Right-of-Way Clearing Assessment, Attachment K-2 to the EFSC’s Final Order at page 16 to 21 (Sept. 27, 2022). 31 See the Agricultural Lands Assessment, Attachment K-1 to EFSC’s Final Order at pages 33 to 47. BARRETTO, DI 35 Idaho Power Company IV. B2H PROJECT COSTS 1 Q. Does Idaho Power have an estimate of the costs 2 of the B2H project? 3 A. Yes. Based on the Company’s most recent 4 forecast dated December 2022, the total cost of Idaho 5 Power’s share of the B2H project on a system basis is 6 approximately , which is made up of costs 7 associated with the transmission facilities including a 8 contingency, overheads, Allowance for Funds Used During 9 Construction (“AFUDC”), property taxes, and local 10 interconnection costs. In addition, the Company estimates 11 ongoing operations and maintenance expenses associated with 12 the B2H project will be approximately $300,000 per year on 13 a system basis. Confidential Exhibit No. 11 to my testimony 14 includes a summary of the B2H project costs by cost 15 category. 16 Q. You indicated the B2H project cost estimate is 17 based on a December 2022 forecast. How has the B2H project 18 cost estimate developed over time? 19 A. A number of updates have been made to the B2H 20 project cost estimates in the past five years, the 21 progression of which I will explain in detail and are also 22 presented in Confidential Exhibit No. 11 for comparison 23 purposes. First, B2H project cost estimates for the 2019 24 IRP through the 2021 IRP were based on a 10 percent 25 BARRETTO, DI 36 Idaho Power Company detailed design/indicative design. 1 Q. What is an indicative design? 2 A. A design starts with an indicative design 3 based on available data and as additional information is 4 made available, such as detailed topography captured by 5 light detection and ranging (“LiDAR”), the design 6 progresses. With more site-specific data, detailed 7 engineering progresses and economization occurs based on 8 on-the-ground data. The 10 percent detailed 9 design/indicative design included selection of a standard 10 tower series and conductor, the ASC proposed route location 11 and length, preliminarily sited towers and access roads, 12 and identified primary station equipment. 13 Q. How does this translate to a cost estimate? 14 A. Based on the design, Owner’s Engineer HDR, 15 Inc. (“HDR”) utilized their utility and industry experience 16 with current market values for materials, equipment, and 17 labor to arrive at the B2H estimate, including experience 18 with the specific towers and conductor BPA has installed 19 that the B2H project is using. They start with preparation 20 of a preliminary transmission line design that locates 21 every tower and access road needed for the project based on 22 the proposed route location and length. The design included 23 the selection of a standard tower series and conductor 24 design for 500-kV lines. HDR accomplished a partial 25 BARRETTO, DI 37 Idaho Power Company material take off for all major items (towers, conductors, 1 foundations, roads, rights-of-way, etc.) using the fewest 2 assumptions possible. 3 In 2021, Idaho Power hired the firm Leidos 4 Engineering, LLC (“Leidos”), to provide engineering 5 services to develop a detailed transmission line design for 6 the project. In 2022, the Company hired the firm Quanta 7 Infrastructure Solutions Group (“QISG”) as the 8 constructability consultant for the project. QISG has 9 significant experience overseeing and managing construction 10 of high voltage transmission projects. Leidos completed a 11 30 percent detailed design package, providing engineering 12 design criteria, the project alignment with structure 13 locations based on LiDAR, and structure tower class 14 development for all structures required for the line. With 15 this 30 percent detailed design package, QISG performed a 16 constructability review of the design and provided a 17 revised cost estimate for the transmission line component 18 of the project based on their expertise. The 30 percent 19 detailed design package and corresponding estimate by QISG 20 was the basis for the cost estimate used in the Company’s 21 Petition for Certificate of Public Convenience and 22 Necessity filed with the Public Utility Commission of 23 Oregon on September 30, 2022, Docket No. PCN 5 (“PCN 5”). 24 Q. Is the cost estimate provided in this case the 25 BARRETTO, DI 38 Idaho Power Company same as provided in the initial filing in PCN 5? 1 A. No. The Company’s initial filing with the 2 Public Utility Commission of Oregon in PCN 5 reflected a 30 3 percent design estimate. In late December, the Company 4 filed supplemental testimony providing a cost update 5 reflecting the 60 percent design package from Leidos, and 6 the estimate provided here is consistent with the December 7 2022 PCN 5 update. The 60 percent design package includes 8 more site-specific constraints to meet height limitations, 9 as well as right-of-way considerations. At this point, the 10 transmission line structure locations are generally 11 confirmed, structure types and class are finalized, and 12 access roads are near finalized. With this 60 percent 13 detailed design package, QISG performed a constructability 14 review of the design and provided a revised cost estimate 15 for the transmission line component of the project based on 16 their expertise. The 60 percent detailed design package 17 and corresponding estimate by QISG was the basis for the 18 cost estimate used in this proceeding. 19 Q. Are the varying percentage levels of detailed 20 design indicative of the percentage accuracy of the cost 21 estimate? 22 A. No. The difference between preliminary design 23 and the levels of detailed design are some of the areas 24 around which assumptions must be made about project 25 BARRETTO, DI 39 Idaho Power Company requirements. As with any large project, the goal is to 1 increase certainty over time and reduce contingencies and 2 unknowns as the project matures. The design percentage is 3 indicative of the unknowns that have been eliminated. 4 Therefore, the B2H project estimate has included a budget 5 for those various unknowns since the beginning. 6 Q. Were any additional adjustments made to the 7 cost estimates received under each of the 10-, 30-, 60 8 percent design packages? 9 A. Yes. For modeling of the 2019 IRP, Idaho Power 10 included a 20 percent contingency on B2H project costs, as 11 is standard and reflective of the status of the overall 12 project which was prior to any pre-construction work and 13 prior to execution of competitively bid contracts for 14 materials or construction. However, for modeling of 15 resources in the 2021 IRP, including the B2H project, no 16 contingency amounts were included. Therefore, it would have 17 skewed the IRP modeling results to have included a 18 contingency amount in the B2H cost estimate. For comparison 19 purposes in Confidential Exhibit No. 11, however, the 20 Company has added a 20 percent contingency to the 2021 IRP 21 B2H project costs. In addition, Idaho Power’s ownership 22 share of the B2H project was updated from 21.21 percent for 23 modeling in the 2019 IRP to 45.45 percent for modeling of 24 B2H project costs in the 2021 IRP. Finally, the cost 25 BARRETTO, DI 40 Idaho Power Company estimate was updated to reflect increased material and 1 labor costs due to inflation and supply chain issues. Idaho 2 Power’s ownership share of the resulting December 2022 B2H 3 project cost estimate is . 4 Q. Does Idaho Power have cost controls in place 5 for the B2H project? 6 A. Yes. The Company has strict project cost 7 controls for internal and external personnel. Regular 8 monthly forecast updates, including the tracking of budgets 9 and schedules, are part of the project controls suites that 10 the project management team employs. During the current 11 preconstruction phase, Idaho Power’s constructability 12 consultant, QISG, aided in certain preconstruction reviews 13 and tasks. This early integration of the construction team 14 allows for constructability feedback, identification of 15 risks, and opportunities to economize the design. As the 16 B2H project transitions into the construction phase, all 17 material and construction services will be competitively 18 bid and be pulled into a guaranteed maximum price (“GMP”) 19 that will serve as the construction pricing if awarded. 20 This GMP is tied to a schedule that Idaho Power and the 21 construction manager will have developed together that the 22 Company, and as a result of the contract, the construction 23 manager will be responsible for meeting that schedule. 24 Milestone dates will be tied to monetary penalties for the 25 BARRETTO, DI 41 Idaho Power Company construction manager if key dates slip. 1 Q. Is the B2H project cost estimate based on 2 executed master contracts for construction of the project? 3 A. No. Idaho Power has not yet selected 4 contractors for the construction phase but anticipates 5 issuing Requests for Proposals for materials and 6 contractors during the first quarter of 2023. In addition, 7 the Company anticipates selecting a construction manager in 8 the third quarter of 2023. The B2H project cost estimate is 9 based on Idaho Power’s most recent forecast of project 10 costs. As described in the direct testimony of Mr. 11 Ellsworth, B2H project costs included in the modeling of 12 the 2021 IRP were reviewed and approved by BPA and 13 PacifiCorp, both of whom have recent 500-kV transmission 14 line construction projects to calibrate against. In 15 addition, Idaho Power worked collaboratively with NV Energy 16 and Southern California Edison to calibrate the B2H project 17 cost estimate using their experience on two recent 500-kV 18 projects. 19 V. CONSTRUCTION OF THE B2H PROJECT 20 Q. Now that the Company has received an EFSC 21 Order and Site Certificate, when does Idaho Power 22 anticipate commencing construction of the B2H project? 23 A. As discussed earlier, in April 2022 the 24 Company contracted with QISG for constructability 25 BARRETTO, DI 42 Idaho Power Company consulting services, who reviewed and analyzed the project 1 details, and subsequently advised that a construction start 2 date in the summer of 2023 is recommended to ensure 3 energization of the line to meet the 2026 resource deficit. 4 Q. Is Idaho Power required to obtain any other 5 regulatory approvals prior to construction of the B2H 6 project? 7 A. Yes. Oregon Revised Statute 758.015 requires 8 a CPCN if condemnation of land or an interest therein is 9 necessary for construction of a transmission line. Idaho 10 Power is currently negotiating with landowners in good 11 faith to obtain options for easements, but the Company 12 anticipates it may need to initiate condemnation 13 proceedings to gain access to certain parcels along the B2H 14 project route. As such, on September 30, 2022, immediately 15 following EFSC’s final decision approving the B2H project 16 subject to certain conditions on September 27, 2022, Idaho 17 Power initiated the PCN 5 proceeding with the Public 18 Utility Commission of Oregon in order to obtain the CPCN in 19 time for construction to commence in 2023. The Public 20 Utility Commission of Oregon is targeting an order by June 21 30, 2023. 22 Q. Is the Company requesting the Commission issue 23 a CPCN by June 30, 2023, in this proceeding as well? 24 A. Yes. Idaho Power is requesting the Commission 25 BARRETTO, DI 43 Idaho Power Company issue a CPCN no later than June 30, 2023, as a final 1 Commission decision is critical to allowing the Company to 2 construct the B2H project in time to meet the 2026 resource 3 deficit. If a Commission’s order in this proceeding is 4 delayed beyond June 2023, Idaho Power may not be able to 5 begin construction in 2023 and accordingly meet the B2H 6 project’s 2026 in-service date. 7 VI. CONCLUSION 8 Q. Please summarize your testimony. 9 A. The B2H project will be vital to the 10 electrical grid and designed to adhere to, and in most 11 cases, exceed, the required codes or standards observed for 12 high voltage transmission line design to establish utmost 13 reliability for the life of the transmission line. As part 14 of the route determination, the Company evaluated numerous 15 potential impacts, including topography, geology, stream 16 crossings, cultural resources, environmental and 17 agricultural uses. After extensive public participation, 18 Idaho Power submitted its final proposed B2H project route 19 including four alternative route segments to the Council. 20 On October 6, 2022, EFSC executed their Final Order and 21 Site Certificate for the B2H project. 22 The B2H project is moving into the preliminary 23 construction phase and construction must start in the 24 summer of 2023 to ensure energization in time to meet the 25 BARRETTO, DI 44 Idaho Power Company 2026 resource deficit identified in Idaho Power’s 2021 1 Integrated Resource Plan. Idaho Power must commence the 2 CPCN proceeding in order to obtain the CPCN in time for 3 construction to commence in 2023. 4 Q. Does this conclude your testimony? 5 A. Yes. 6 // 7 // 8 // 9 // 10 // 11 // 12 // 13 // 14 // 15 // 16 // 17 // 18 // 19 // 20 // 21 // 22 // 23 // 24 // 25 BARRETTO, DI 45 Idaho Power Company DECLARATION OF LINDSAY BARRETTO 1 I, Lindsay Barretto, declare under penalty of 2 perjury under the laws of the state of Idaho: 3 1. My name is Lindsay Barretto. I am employed 4 by Idaho Power Company as the 500kV and Joint Projects 5 Senior Manager. 6 2. On behalf of Idaho Power, I present this 7 pre-filed direct testimony and Exhibit Nos. 8 through 11 in 8 this matter. 9 3. To the best of my knowledge, my pre-filed 10 direct testimony and exhibits are true and accurate. 11 I hereby declare that the above statement is true to 12 the best of my knowledge and belief, and that I understand 13 it is made for use as evidence before the Idaho Public 14 Utilities Commission and is subject to penalty for perjury. 15 SIGNED this 9th day of January 2023, at Boise, Idaho. 16 17 Signed: 18 19 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-01 IDAHO POWER COMPANY BARRETTO TESTIMONY EXHIBIT NO. 8 Transmission Tower Components        BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-01 IDAHO POWER COMPANY BARRETTO TESTIMONY EXHIBIT No. 9 Land Use Approvals and Permits Required for the B2H Project    Permit or Approval Regulatory  Authority  Federal /State/  Local  Included  in EFSC  Site  Certificate  Status  Date   Issued or  Expected  Bureau of Land  Management ROW Grant  U.S. Bureau of Land  Management Federal No Issued January 2018  Cultural Resource Use  Permit and Site‐Specific  Authorizations  U.S. Bureau of Land  Management Federal No Issued June 2022  Permit for Archaeological  Investigations  U.S. Bureau of Land  Management Federal No Issued Contractor‐held1  Paleontological Resources  Use Permit  U.S. Bureau of Land  Management Federal No Issued Contractor‐held  Navy Easement U.S. Department of  Navy Federal No Issued March 2020  Forest Service Easement U.S. Forest Service Federal No Issued May 2019  Special Use Authorization  for Archaeological  Investigations  U.S. Forest Service  Federal No Issued July 2022  Archaeological Excavation  Permit  Oregon State  Historic  Preservation Office  State No Issued August 2022  Energy Facility Site  Certificate  Oregon Energy  Facility Siting  Council  State Yes Issued  October 2022  Baker County Land Use  Permits  Baker County Local Yes Issued  January 2023  Malheur County Land Use  Permits  Malheur County Local Yes Issued  January 2023  Morrow County Land Use  Permits  Morrow County Local Yes Pending  March 2023  Umatilla County Land Use  Permits  Umatilla County Local Yes Pending  March 2023  Union County Land Use  Permits  Union County Local Yes Issued  December 2022  Federal Notice of  Proposed Construction or  Alteration  Federal Aviation  Administration Federal No Pending  Prior to  Construction  1 Contractor‐held permits are held by Idaho Power’s contractors as part of their ordinary course of business rather  than being obtained specifically for B2H.  Permit or Approval Regulatory  Authority  Federal /State/  Local  Included  in EFSC  Site  Certificate  Status  Date   Issued or  Expected  Clean Water Act   Section 404, Nationwide  Permit 572  U.S. Army Corps of  Engineers Federal No Pending  Prior to  Construction  Special Use Permit for  Logging Activities  U.S. Forest Service Federal No Pending  Prior to  Construction  Removal‐Fill Permit Oregon  Department of  State Lands  State Yes Pending  Prior to  Construction  Oregon Notice of  Proposed Construction or  Alteration  Oregon  Department of  Aviation  State No Pending  Prior to  Construction  National Pollutant  Discharge Elimination  System Permit 1200‐C  Oregon  Department of  Environmental  Quality  State No Pending  Prior to  Construction  National Pollutant  Discharge Elimination  System Permit 1200‐A  Oregon  Department of  Environmental  Quality  State No Pending  Prior to  Construction  Air Contaminant  Discharge Permit  Oregon  Department of  Environmental  Quality  State No Pending  Prior to  Construction  Permit to Operate Power  Driven Machinery  Oregon  Department of  Forestry  State No Pending  Prior to  Construction  Burn Permit Oregon  Department of  Forestry  State No Pending  Prior to  Construction  Plan for Alternate Practice Oregon  Department of  Forestry  State No Pending  Prior to  Construction  Permit to Construct a  State Highway Approach  Oregon  Department of  Transportation  State No Pending  Prior to  Construction  Oversize Load Movement  Permit/Load Registration  Oregon  Department of  Transportation  State No Pending  Prior to  Construction  Permit to Occupy or  Perform Operations Upon  a State Highway  Oregon  Department of  Transportation  State No Pending  Prior to  Construction  2 Nationwide Permit 57 was formerly known as Nationwide Permit 12 prior to being renumbered in 2021.  Permit or Approval Regulatory  Authority  Federal /State/  Local  Included  in EFSC  Site  Certificate  Status  Date   Issued or  Expected  Fish Passage Plan Update  (if needed)  Oregon  Department of Fish  and Wildlife  State Yes Pending  January 2023  Road Approach Permit Baker County Local No Pending  Prior to  Construction  Work in County Right‐of‐ Way Permit  Baker County Local No Pending  Prior to  Construction  Flood Plain Development  Permit  Baker County  Local No Pending   Prior to  Construction  Permit to Occupy or  Perform Operations upon  Public Roads  Malheur County  Local No Pending   Prior to  Construction  Flood Plain Development  Permit  Malheur County  Local No Pending   Prior to  Construction  Utility Crossing Permit Morrow County  Local No Pending   Prior to  Construction  Access Approach Site  Permit  Morrow County  Local No Pending   Prior to  Construction  Construction Permit to  Build on Right‐of‐Way  Morrow County  Local No Pending   Prior to  Construction  Flood Plain Development  Permit  Morrow County  Local No Pending   Prior to  Construction  Installation of Utilities on  County and Public Roads  Permit  Umatilla County  Local No Pending   Prior to  Construction  Road Approach and  Crossing Permit  Umatilla County  Local No Pending   Prior to  Construction  Flood Plain Development  Permit  Umatilla County  Local No Pending   Prior to  Construction  Road Approach Permit Union County  Local No Pending   Prior to  Construction  Work in County Right‐of‐ Way Permit  Union County  Local No Pending   Prior to  Construction  Flood Plain Development  Permit  Union County  Local No Pending   Prior to  Construction  Conditional Use Permit Owyhee County  (Idaho) Local No Pending  Prior to  Construction  Certificate of Public  Convenience and  Necessity  Idaho Public  Utilities  Commission State No Pending  Prior to  Construction  Certificate of Public  Convenience and  Necessity  Oregon Public  Utilities  Commission State No Pending  Prior to  Construction  BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-01 IDAHO POWER COMPANY BARRETTO TESTIMONY EXHIBIT NO. 10 B2H Project Proposed Route BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-23-01 IDAHO POWER COMPANY Confidential BARRETTO TESTIMONY EXHIBIT NO. 11