Thursday, April 2, 2009

Why still on Fast Track?

My name is Jean Findley, and I am a long-time resident (32 years) of Malheur County. Let me begin by thanking the Oregon Public Utilities Commission (OPUC) for coming to Eastern Oregon for this hearing; we appreciate your responsiveness to our request for a hearing in Ontario.

I would like to speak to the question of why the Boardman to Hemingway (B2H) 500 kV transmission line must be built now, or whether it could wait for other issues to be factored in for construction at a later time.

We here in Malheur County were told at the October, 2008, scoping meeting that this line is on what is called a ‘fast track’ for construction, meaning that the more standard prolonged and careful deliberations for need and siting will be hurried through for B2H. I am concerned that this line remains on the ‘fast track,’ especially in light of the various testimonies we will be hearing tonight and before need is established.

How do we know the line is still on ‘fast track’? On March 9, 2009, Idaho Power Company (IPC) announced that all routing lines on all maps were gone; routing was to begin anew with citizens’ task force groups with line placement not finalized until December, 2009.

However, at that same meeting, IPC stated that they would not wait to present their 2009 Integrated Resource Plan (IRP), which will be prepared and available in June of this year, to OPUC – that the addendum would have to do; that the National Environmental Policy Act (NEPA) process would continue as scheduled; and that the dates projected for Oregon’s Energy Facilities Siting Counsel (EFSC) involvement were still as scheduled.

In the addendum to the IRP itself, IPC calls filing of an addendum ‘unusual.’ (Page 1) Why not wait to file a complete and thorough document to OPUC, especially if we are in a new phase of line siting? On the NEPA process, it is obviously still on-going based on a call I received just last week from the Bureau of Land Management (BLM), where I retired as botanist last year, asking which rare plant lists from Oregon Natural Heritage Program I had used, because BLM needed to send TetraTech (IPC’s environmental contractor) plant lists for field work they are conducting this spring, even though all routes are theoretically off the table.

If need is not established for this line and routes have yet to be determined, it seems that time tables for EFSC also cannot be followed at this point, again arguing for taking this project off the ‘fast track’ and considering more deliberately whether this line should be built at a later time or at all.

The Addendum itself needs to be amended. The map on page 5 showing the corridor and routes is no longer accurate. At least two citizens’ groups have proposed an alternate route following a significant portion of the federal Westwide Energy Corridor to Buchanan, Oregon. The Record of Decision for this corridor was issued on March 24, 2009, and the need for these corridors was based on a thriving, growing economy. In any case, all routes are off the table at this point in time. IPC also announced on March 9, 2009, that the inline Sand Hollow substation, identified on page 6 of the Addendum, is no longer a critical feature of this line. It is possible that they will be identifying Langley Gulch as the new location for an inline substation, again indicating that the Addendum should be amended.

Other reasons also contribute to the need to take B2H off the ‘fast track,’ and more careful deliberations need to be made regarding whether or not the line should be built now (in the next three to five years) or in future years (six to 20) or ever. IBM experts in a recent television advertisement stated that half the power produced in the United States does not reach a light bulb. These huge 500 kV lines experience huge electrical losses in the course of transmission. In Table 1 of Volume 9, Issue 5 (October-November, 2003) of The Industrial Physicist, Eric J. Lerner shows that 100 miles of 500 kV line carries 1300 MW of power, while that same line over 400 miles only carries 600 MW. This is an enormous loss of more than half the electrical power generated. Currently, a move is afoot to develop a “smart grid” to help compensate for this kind of power loss by keeping production closer to usage. Super-conducting wires are also beginning to be used to aid in reducing transmission loss. With the B2H line not necessary to meet local needs at this time based on considerable testimony we will be hearing tonight, we can surely wait for a few years to see how “smart grid” and super-conducting developments proceed, which would certainly make a line of this length far more efficient, if it is in fact necessary.

Localized generation or dispersed generation also contributes to lack of need for this line to meet local needs at this time. Eastern Oregon is ideally suited for solar generation, and there are geothermal and wind resources in the area to be developed. As these resources become developed, IPC now has the capabilities of the Hemingway Substation to tie the production of dispersed generation not needed locally to the Pacific Power and Light 500 kV line which will connect Hemingway with the California-Oregon border.

The emissions issues regarding IPC’s coal-fired plant at Boardman and involvement of the Environmental Protection Agency and various environmental groups in the problems at that plant need to be resolved before this B2H line is put in place also.

In addition, the slow-down and potential recovery of the economy both here and abroad will continue for many years. This gigantic economic ship will be turned very, very slowly. There is still a credit crisis for countless individuals in this country, and the rampant, often reckless, spending by the American consumer is not going to return any time soon. The banking system remains in shambles. Even if need for electricity rises in the future, the rise will be much slower than we have seen in the super-heated economic environment of the last ten years. Any pick-up in the economy will not return us to the same situations we have seen these last ten years; things will be different this time. We were burned, and we have learned; we will be much more cautious, both as consumers and as lenders. The economic morass of 2008/2009 and beyond is not just a little blip; we are seeing fundamental changes at all levels in the economic systems of this country, all of which must be factored into any sort of pressing need for the B2H line.

At the very least, B2H needs to be taken off the ‘fast track.’ The IRP addendum should be dismissed on prudential grounds, the full IRP must be evaluated, and OPUC needs to strongly consider the need for this line at the present time. We here in Malheur County who have studied these issues at some length do not believe the data show that this line is needed now in this service area. However, if IPC wants to construct B2H on public land, rather than on private exclusive farm use-zoned land, we would gladly step aside in Malheur County and support IPC’s participation in the larger wheeling picture.

Respectfully submitted,

Jean Findley
March 26, 2009