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Home My WebLink About200407161st Request of ID Power to Eagle River.pdf\I~' ,....\...1- t... BARTON L. KLINE ISB #1526 MONICA B. MOEN ISB #5734 Idaho Power Company O. Box 70 Boise, Idaho 83707 Phone: (208) 388-2692 FAX: (208) 388-6936 ! L,t.L ill ~~= n rH~ It H . ~' ~ l.. ~v'1 yUl.. "I" ,) i.U fLjL;LIC Jf IL tiiES COr+'I1'"itssfON Attorneys for Idaho Power Company 1221 West Idaho Street Boise , Idaho 83702 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IDAHO POWER COMPANY CASE NO. IPC-04- Complainant IDAHO POWER COMPANY' FIRST PRODUCTION REQUEST TO EAGLE RIVER, LLC CITY OF EAGLE, IDAHO Respondent. COMES NOW , Idaho Power Company ("Idaho Power" or "the Company and, pursuant to IPUC Rule of Procedure 225, requests that Eagle River, LLC Intervenor in the above-referenced matter, provide responses to the following discovery requests no later than Monday, August 2 2004. This Production Request is to be considered continuing and ongoing and Eagle River, LLC is requested to provide, by way of supplemental responses , any and all additional documents that it or any person acting on its behalf may later obtain that IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO EAGLE RIVER, LLC Page will augment the documents or information produced. In accordance with IPUC Rule of Procedure 228 , for each item , please indicate the name of the person(s) preparing the answer along with the job title of such person(s) and the witness who can sponsor the answer at hearing. REQUEST NO.1: Eagle River, LLC Witness Carlise testifies on page of his direct testimony that construction of an overhead 138-kV transmission line along the mile-long northern boundary of the Eagle River Development will degrade the Development "to the point that land values will fall and building standards will be forced down." Please provide evidence in support of this assertion. REQUEST NO.2: Please quantify the diminution in value that the Eagle River Development will suffer as generally alleged by Eagle River, LLC Witness Carlise in his direct testimony in this matter if the 138-kV transmission line is constructed as proposed by Idaho Power Company. REQUEST NO.3: Please provide evidence to substantiate Eagle River LLC Witness Carlise s claim that the presence of a 138-kV transmission line along the northern boundary of the Eagle River Development will reduce the Development "to a more average quality development, with much less desirability and appeal to the high- end businesses and customers Eagle River is seeking to attract."Carlise Direct Testimony at 10-11. REQUEST NO.4: Please provide evidence to substantiate Eagle River LLC Witness Carlise s claim that the presence of a 138-kV transmission line along the northern boundary of the Eagle River Development will discourage the development of general office/medical office uses within the Development as stated on page 11 , lines IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO EAGLE RIVER, LLC Page 2 3 of his direct testimony. REQUEST NO.5: Please provide evidence to substantiate Eagle River LLC Witness Carlise s claim that the presence of a 138-kV transmission line along the northern boundary of the Eagle River Development will delay the build-out period of the Development as asserted on page 11 , lines 8-, of his direct testimony.Please quantify the extent of any delay that is anticipated and provide evidence to support that assertion. REQUEST NO.6: Please provide direct evidence to substantiate Eagle River, LLC Witness Carlise s claim that the presence of 138-kV transmission lines along the northern boundary of the Eagle River Development will result in a loss " investment of the cost and expense of the high-end amenities which (are) incorporated into (the) Development" as asserted on page 11 , lines 10-, of his direct testimony. REQUEST NO.7: Eagle River, LLC Witness Carlise testifies on page 11 lines 12-, that Eagle River relied upon the representations made in the Eagle Comprehensive Plan. Please identify the representations in the Eagle Comprehensive Plan on which Eagle River, LLC relied. Please confirm that the Eagle Comprehensive Plan encourages placement of electric utility facilities on public street and road rights-of-way and corridors. REQUEST NO.Please identify with specificity the nature of the reliable technology" referenced by Eagle River, LLC Witness Carlise on page 12, lines 18-, of his direct testimony "that would not require Idaho Power Company to IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO EAGLE RIVER, LLC Page 3 construct the massive 138-kV poles and lines.Id. at lines 19-20. REQUEST NO.Please identify with specificity the source of information relied upon by Eagle River, LLC Witness Carlise when he asserts on page , lines 20-, that alternative "reliable technology . . . would not cost any more than Idaho Power Company current proposal to construct the lines along the Eagle Bypass. REQUEST NO.1 0:Please name all of the communities generally referenced by Eagle River, LLC Witness Carlise in his direct testimony on page 12 lines 22-, that have used the alternative "reliable technology that would not require Idaho Power to construct the massive 13-kV poles and lines.Id. at lines 19-20. REQUEST NO. 11: Please describe the bases for Eagle River LLC Witness Carlise s assertion on page 13, lines 3-, that "Idaho Power Company did not consider alternative technologies as - a means of mitigating the impacts of its transmission line. DATED at Boise , Idaho, this 15th day of July 2004. ~- (fJ , MONICA B. MOEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S FIRST PRODUCTION REQUEST TO EAGLE RIVER, LLC Page 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 15th day of July 2004, I served true and correct copies of the above and foregoing IDAHO POWER COMPANY'FIRST PRODUCTION REQUEST TO EAGLE RIVER LLC to the following parties: Donald L. Howell, II Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington Street O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered S. Mail Overnight Mail FAX Susan Buxton Moore Smith 225 N. 9th Street, Suite 420 Boise , Idaho 83702 Hand Delivered S. Mail Overnight Mail FAX City of Eagle O. Box 1520 Eagle , Idaho 83616 Hand Delivered S. Mail Overnight Mail FAX B. Newel Squyres Mary V. York Holland & Hart, LLP Suite 1400, U.S. Bank Plaza 101 S. Capitol Boulevard O. Box 2527 Boise, ID 83701 Hand Delivered S. Mail Overnight Mail FAX Eagle River, LLC c/o Ennis Dale 485 E. Riverside Drive Eagle, ID 83616 Hand Delivered U. S. M ai I Overnight Mail FAX ~~ 1ft MONICA B. MOEN CERTIFICATE OF SERVICE