200408201st Response of PacifiCorp to Staff.pdf

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August 19, 2003
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
RE:Idaho P AC-04-
IPUC 1st Data Request (1)
Please find enclosed PacifiCorp s Response to IPUC 1 st Data Request (1).
If you have any questions, please call me at [phone].
Sincerely,
Bob Lively
Manager, Regulation
Enclosure
825 E. Multnomah St.
Portland, OR 97232
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Proud Sponsor of the
200212004 u.S. Olympic Team
ill P AC- E-04-4/PacifiCorp
August 19 2004
IPUC Data Request
IPUC Data Request
Please explain why Applicant-Built Line Extensions are not an option for the
following circumstances: relocations, conversions from overhead to underground
going from single-phase to three-phase, or increasing the capacity of facilities.
Response to IPUC Data Request
The Company s long standing practice is that Applicant Built Line Extensions are
only for new construction. All of the circumstances described above, including
relocations, conversions from overhead to underground, going from single-phase
to three-phase, and increasing the capacity of facilities, involve existing
Company-owned facilities, and thus are not options for Applicant-Built Line
Extensions.
The Company met with IPUC Staff in Boise on March 10, 2004, to address
applicant built lines. It was agreed by both Staff and Company personnel that any
company has the right to maintain, repair, modify, etc. their own facilities.
The Company maintains all facilities on Company s side of the point of
interconnection. This is consistent with the Company s right to maintain its own
facilities and assures customer safety. In P AC-03- 7, the Company provided
responses to the Idaho Public Utility Commission on June 17 2003 regarding
why the Company prohibits customers from hiring their own contractors to
perform relocations and/or alterations of electrical distribution facilities. A
summary of the Company s earlier response is provided below.
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 s overhead line
safety act limits contractors from working within 10 feet of a standard distribution
line. While not all relocations require such work, many do. The safety risk and
potential for liability resulting from electrical contact that could occur by
qualified or non qualified individuals who are working under the direction of an
applicant is higher for relocations an alternations 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.
There is also the potential for claims against the Company due to failure to
provide service. At a minimum, in addition to connecting the new line to the grid
relocations or alterations have the additional requirement of de-energizing the old
line, switching load and removing the old line. This additional work requires
additional coordination and greater exposure to problems.