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HomeMy WebLinkAbout200306181st Response of PacifiCorp to Staff.pdfP~(i\!C"'\:"'vLli' 825 N.E MuItnomah Portland, Oregon 97232 (503) 813-5000 f;;)L::J :1 ~, J ,"Ie i\ M1 9: 4 , PACIFICORP ' '-" '- ':- ~ , ;;" ; CII!.. jil:.~ Vji.'"";jlC'c I.1I.. I I dvv PACIFIC POWER UTAH POWER June 17, 2003 Jean Jewell, Commission Secretary Idaho Public Utilities Commission 472 W. Washington Boise, ID 83702-5983 RE:Idaho Case No. PAC-03-, Del Ray Holm vs. PacifiCorp IPUC Data Requests 1- Enclosed please find an original and one copy ofPacifiCorp s Responses to IPUC' Data Requests 1-7. All of the responses have been prepared and sponsored by Rob Stewart, Regulatory Consultant, in consultation with counsel, John Erikkson. If you have any questions, please call Carole Rockney at (503) 813-7408. Sincerely, C~~e~lf' /\ Carole Rockney Director, Regulation Enclosures cc Service List CERTIFICATE OF SERVICE I hereby certify that I caused the foregoing document to be served on the following named person(s) on the date indicated below by mailing to said person(s) a true copy thereof, contained in a sealed envelope, addressed to said person(s) at their last known addressees) indicated below. Robert C. Huntley Huntley Park LLP PO Box 2188 Boise, ID 83701 Del Ray Holm 2725 E 500 N Reberts, ID 83444 John Erikkson Stoel Rives 1 Utah Center, Suite 1100 201 S Main St Salt Lake City, UT 84111 D Douglas Larson VP Regulation, PacifiCorp 1 Utah Center, Suite 2300 201 S Main St Salt Lake City, UT 8 111 Mark Tucker Regulatory Filing Coordinator Dated: June 17 2003 P AC-03- 7/PacifiCorp June 17, 2003 IPUC I st Set Data Request IPUC Data Request 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 Response to IPUC Data Request 1 There are several reasons customers should not have the option to perform relocations or alterations of electrical distribution facilities. One reason is the safety and liability issues, discussed in responses to Requests 2 and 3. Also allowing such an option can lead to problems with respect to the Company ability to meet its service obligations. For instance, if a customer is performing relocation or alteration work and causes a service outage, other customers will likely look to PacifiCorp regarding that outage. Similarly, a customer may want to perform an alteration or relocation of a line, serving another seasonal customer during the "off season." Ifthe customer does not complete the work in time, it will be PacifiCorp that would be subject to a claim of not meeting its service obligation to the seasonal customer. (The Company recently had a request ofthis nature in Utah.) Further, additional administrative burdens would result from allowing that option, not only in the form of administering contracts providing for the customer-built relocations or alterations, but also in dealing with the types of complaints raised in this case. Neither the Company, nor the Commission, should be burdened with complaints regarding the Company s construction and equipment specifications, which would likely result from allowing customers additional customer-built options. This response was prepared by Rob Stewart, Regulatory Consultant, in consultation with counsel, John Erikkson. P AC-03- 7/PacifiCorp June 17, 2003 IPUC 1 st Set Data Request 2 IPUC Data Request 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. Response to IPUC Data Request 2 Yes. Working within proximity of energized power lines is a clear safety risk. Hand digging is required within 2 feet of an insulated buried line. Idaho overhead line safety act (Chapter 24, Title 55, Idaho Code) limits contractors from working within 10 feet of a standard distribution line. Though not all relocations require such work, many do. The safety risk and potential for liability claims resulting from electrical contact that could occur by qualified or non-qualified individuals who are working under the direction of an applicant, but to build a facility for the Company, would be higher for relocations and alterations simply by virtue of the fact that more of that work would be in closer proximity to energized facilities than is the case with construction of new line extensions. As currently applied applicant build lines are for new facilities that extend where there are no Company facilities, thus avoiding work in proximity of Company facilities. This response was prepared by Rob Stewart, Regulatory Consultant, in consultation with counsel, John Erikkson. P AC-03- 7/PacifiCorp June 17, 2003 IPUC 1 st Set Data Request 3 IPUC Data Request 3 Does PacifiCorp believe there is any different liability associated with contractors constructing new facilities as sopposed 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 ofliability. Response to IPUC Data Request 3 Yes. Please see the response to request no. 2. There is also the potential for claims against the Company due to failure to provide service, as described in response to Request No.1. At a minimum, in addition to connecting the new line to the electrical grid, relocations or alterations have the additional needs of de- energizing the old line, switching the load from the old line to the new line, and removal of the old line. This additional work requires additional coordination and thus greater exposure to coordination problems and subsequent complaints as well as potential liability. This response was prepared by Rob Stewart, Regulatory Consultant, in consultation with counsel, John Erikkson. P AC-03- 7/PacifiCorp June 17, 2003 IPUC 1 st Set Data Request 4 IPUC Data Request 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? Response to IPUC Data Request 4 The Company is not aware of such a protocol, and does not believe it would be reasonable to pursue such a protocol. See responses to Request Nos. 2 and 3. This response was prepared by Rob Stewart, Regulatory Consultant, in consultation with counsel, John Erikkson. P AC-03- 7/PacifiCorp June 17 2003 IPUC 1 5t Set Data Request 5 IPUC Data Request 5 Are applicant-hired contractors ever allowed to energize, de-energize or perform work on energized lines? If yes, please explain the circumstances. Response to IPUC Data Request 5 No. This response was prepared by Rob Stewart, Regulatory Consultant, in consultation with counsel, John Erikkson. P AC-03- 7/PacifiCorp June 17, 2003 IPUC 1 st Set Data Request 6 IPUC Data Request 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)? Response to IPUC Data Request 6 Yes. As to engineering and specifications, PacifiCorp does not alter design based on who is anticipated to perform the construction of a line, nor does it anticipate doing so. Engineering and specifications - Section Al of the applicant built line contract states that PacifiCorp designs the extension. This design is the same whether built by an applicant or PacifiCorp, and the same should hold true for applicant-built alterations/relocations. From PacifiCorp s perspective, due the potential safety, liability and operational conflict issues, the inspection and administration required for an applicant relocation and/or alteration would be much greater than for applicant-build new construction. One reason the administrative burden is increased is due to the fact that there is a salvage credit. If the applicant performs the removal, inspections, delivery of salvaged materials and potential damage assessment becomes an issue. Company removes the facilities, coordination becomes an issue. The more coordination required the greater the difficulty in estimating the costs of PacifiCorp supplied labor and time. This response was prepared by Rob Stewart, Regulatory Consultant, in consultation with counsel, John Erikkson. P AC-03- 7/PacifiCorp June 17 2003 IPUC 1 st Set Data Request 7 IPUC Data Request 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? Response to IPUC Data Request 7 Yes, there are differences in the required qualifications. For applicant-built lines the applicant or the contractor for the applicant must obtain a general liability insurance policy for a minimum of $1 ,000 000, and supply a certificate naming the Company as an "additionally insured". No specific contractor requirements beyond that are required. In addition inspections by qualified Company personnel are required to insure that the work meets quality standards. For relocations or alteration of existing facilities (requiring work on energized facilities or in proximity to energized facilities) all workers must be journeymen linemen. Apprentice linemen may be included under the programs established for apprenticeships. Additionally if they are working for a contractor there are additional contractual indemnity and insurance requirements, above and beyond those required for applicant built line applicants. This response was prepared by Rob Stewart, Regulatory Consultant, in consultation with counsel, John Erikkson.