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Home My WebLink About200305291st Request of Staff to PacifiCorp.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 IDAHO BAR NO. 1895 RECEIVED . .- ~.. ZO03 HAY 29 Pt1 ~: iL:l ""u ,LiLLi!; UTIL!T!i::S C0I1r-1ISSION Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION DEL RAY HOLM CASE NO. PAC-03- Petitioner FIRST PRODUCTION REQUEST OF THE PACIFICORP DBA UTAH POWER & LIGHT COMMISSION STAFF COMPANY TO P ACIFICORP Respondent. The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Scott Woodbury, Deputy Attorney General, requests that PacifiCorp provide the following documents and information, pursuant to Rule 225 of the Idaho Public Utilities Commission Rules of Procedure, IDAPA 31.01.01 , on or before THURSDAY, JUNE 12 2003. This Production Request is to be considered as continuing, and PacifiCorp is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that will augment the documents produced. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. For FIRST PRODUCTION REQUEST TO P ACIFICORP MAY 29 2003 all responses to the following requests, please provide all workpapers, diskettes (3.5 in.) and all underlying formulas in Excel (2000 version) language. Request No.1: Please explain the Company s reasons (other than the approved tariff prohibits it) for prohibiting customers from hiring their own contractors to perform relocations and/or alterations of electrical distribution facilities. Request No.2: Does PacifiCorp believe there is any different safety risk associated with contractors constructing new facilities as opposed to performing relocations and/or alterations? If yes, please explain. Please provide copies of any studies, articles or reports that the Company has reviewed or relied on in its assessment of safety risk. Request No.3: Does PacifiCorp believe there is any different liability associated with contractors constructing new facilities as opposed to performing relocations and/or alterations? If yes, please explain. Please provide copies of any studies, articles or reports that the Company has reviewed or relied on in its assessment of liability. Request No.4: Is there a protocol that could be established to de-energize existing facilities, permit applicant-hired contractors to perform relocations and/or alterations, then to re-energize facilities? Request No.5: Are applicant-hired contractors ever allowed to energize, de-energize or perform work on energized lines? If yes, please explain the circumstances. Request No.6: From PacifiCorp s perspective, are there any differences in the engineering, specifications, inspection or administration required for applicant-built new facilities as opposed to applicant-hired contractors performing relocations and/or alterations (if permitted in the tariff)? Request No.7: Does PacifiCorp believe that any contractor hired for an applicant-built line could also perform a relocation or alteration of existing facilities, or are there differences in the required qualifications? FIRST PRODUCTION REQUEST TO P ACIFICORP MAY 29, 2003 Dated at Boise, Idaho, this f)c;rt'hay of May 2003. Scott Woodoury Deputy Attorney General Technical Staff: Rick Sterling S W: RPS:j olumi sc/prdregipaceO3. 7 swrps FIRST PRODUCTION REQUEST TO P ACIFICORP MAY 29 2003 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF MAY 2003 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP IN CASE NO. PAC-03-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: ROBERT C HUNTLEY HUNTLEY PARK LLP PO BOX 2188 BOISE, ID 83701 DEL RAY HOLM 2725 E 500 N ROBERTS, ID 83444 JOHN ERIKSSON STOEL RIVES BOLEY ET AL 1 UTAH CENTER, SUITE 1100 201 S MAIN ST. SALT LAKE CITY, UT 84111 D DOUG LARSON VP REGULATION P ACIFICORP 201 S MAIN ST., SUITE 2300 SALT LAKE CITY, UT 84111 DATA REQUEST RESPONSE CENTER ACIFICORP 825 NE MULTNOMAH STE 800 PORTLAND OR 97232 a1,SE T Y CERTIFICATE OF SERVICE