20170501Staff to Coxcom 1-2.pdf

CAMILLE CHzuSTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. IOI77
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
CERTIFICATE OF PUBLIC COIWENIENCE
AND NECESSITY TO CONTRUCT SYSTEM
IMPROVEMENTS FOR WOOD RIVER
VALLEY CUSTOMERS.
CASE NO. IPC.E-I6-28
COMMISSION STAFF'S
RESPONSE TO THE F'IRST
PRODUCTION REQUEST OF
coxcoM, LLC
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Camille Christen, Deputy Attorney General, responds as follows to CoxCom, LLC's First
Production Request to Commission Staff.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
COXCOM,LLC I MAY 1,2017
STAFF WITNESS RANDY LOBB WILL BE ABLE TO ANSWER QUESTIONS
ABOUT OR SPONSOR THE ANSWERS TO REQUEST NOS. 1-2, BELOW.
REQUEST NO. 1: If Idaho Power Company constructs new facilities as described in its
application in this matter subsequent to whatever permitting processes ultimately the law
requires, do you object to the construction of those facilities such that they provide space for pole
attachments of Cox's facilities that are currently attached to the Idaho Power facilities which will
be replaced as described in the application?
STAFF RESPONSE NO. 1: In general, Staff does not object to the construction of the
facilities such that they provide space for pole attachments of CoxCom's facilities. Without
knowing whether CoxCom and Idaho Power are in agreement about the rates, terms or conditions
for pole attachments, or cost of production of space needed for the attachments, Staff is unable to
provide its informed position about such arrangement. Staff would need additional information
if it were to consider developing a position, such as whether CoxCom and Idaho Power are in
agreement or information on how the attachment of CoxCom's facilities might impact the
project.
REQUEST NO. 2: If your answer to Request No. 1 is "Yes," please detail those
objections with particularity, the reasons for the objections, and how in your opinion those
objections may be met while simultaneously allowing the attachment of Cox's facilities on Idaho
Power Company's replacement facilities.
STAFF RESPONSE NO. 2: Commission Staff does not have a position on the question
posed in Request No. 1 and so this request is not applicable.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
COXCOM,LLC 2 MAY 1,2017
{DATED at Boise, Idaho, this I day of May 2017
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Camille Christen
Deputy Attorney General
Technical Staff: Randy Lobb
i:umisc/intgl6.2 Staff l" Response to CoxCom, LLC
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
COXCOM,LLC J MAY 1,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS lst DAY OF MAY 2017, SERVED
THE FOREGOING COMMISSION STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF COXCOM, LLC IN CASE NO. IPC-E-16-28, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN E WALKER
LEAD COI.INSEL
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
dockets@idahopower. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-mail : [e-mail]
MATTHEW A JOHNSON
Wm. F GIGRAY
WHITE PETERSON GIGRAY
& NICHOLS PA
57OO E FRANKLIN RD STE 2OO
NAMPA ID 83687
E-mail : [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE TD 83702
E-mail: [e-mail]
E.MAIL ONLY
SIERRA CLUB
ZACK WATERMAN
zack. waterman@ sieraclub. org
TIM TATUM
VP REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
KIKI LESLIE A TIDWELL
3OO LET'ER BUCK ROAD
HAILEY ID 83333
E-mail : [e-mail]
LAURA MIDGLEY
231 Y ALLEY CLUB DR
HAILEY ID 83333
E-mail: midgley22l [e-mail]
KELSEY JAE NLTNEZ
KELSEY JAE NLINEZLLC
920 N CLOVER DR
BOISE ID 83703
E-mail : kelsey@kelseyj aenunez.com
MICHAEL HECKLER
3606 N PROSPECT WAY
GARDEN CITY TD 83714
E-mail: Michael.p.heckler(@smail.com
CERTIFICATE OF SERVICE
COXCOM LLC
CIO C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 8370I
E-mail: [e-mail]
CERTIFICATE OF SERVICE