HomeMy WebLinkAbout20120518Affidavit Lowry.pdfLISA D. NORDSTROM (ISB No. 5733)
PATRICK A. HARRINGTON (ISB No. 3423)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-5825
Facsimile: (208) 388-6936
Inordstromcidahopower.com
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RECEIVED
2917 MAY 18 P11 141 " 06
rHO UBLtC
UTILtTIES / SS1O4
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO MODIFY ITS RULE H
LINE EXTENSION TARIFF RELATED TO
NEW SERVICE ATTACHMENTS AND
DISTRIBUTION LINE INSTALLATIONS
CASE NO. IPC-E-08-22
AFFIDAVIT OF DAVID R. LOWRY IN
SUPPORT OF IDAHO POWER
COMPANY'S BRIEF ON
RECONSIDERATION REGARDING
RELOCATION REQUESTS FROM
THIRD PARTIES
STATE OF IDAHO )
) ss.
County of Ada
)
/?
I, David R. Lowry, having been duly sworn to testify truthfully, and based upon
my personal knowledge, state the following:
1.I am an employee of Idaho Power Company ("Idaho Power"). I am
employed by Idaho Power as Project Design Leader.
2.Attached as Exhibit A to this Affidavit is a document entitled "Idaho
Power Relocations from Road Rights-of-Way for Third Parties." Exhibit A provides
examples of projects in recent years where Idaho Power has relocated facilities located
AFFIDAVIT OF DAVID R. LOWRY IN SUPPORT OF IDAHO POWER COMPANY'S BRIEF
ON RECONSIDERATION REGARDING RELOCATION REQUESTS FROM THIRD PARTIES -1
in the road right-of-way at the request and expense of a third party. In all of the projects
listed, the third party made its relocation request and relocation payment directly to
Idaho Power.
3. I am familiar with the projects listed on Exhibit A through personal
experience and through discussions with the Idaho Power field personnel who worked
on the projects and attest to the accuracy of the information provided in Exhibit A.
FURTHER YOUR AFFIANT SAYETH NAUGHT.
DATED this 18th day of May, 2012.
R. LOWRY
SUBSCRIBED AND SWORN to before me this 18th day of May 2012.
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AFFIDAVIT OF DAVID R. LOWRY IN SUPPORT OF IDAHO POWER COMPANY'S BRIEF
ON RECONSIDERATION REGARDING RELOCATION REQUESTS FROM THIRD PARTIES -2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 18th day of May, 2012 I served a true and correct
copy of the AFFIDAVIT OF DAVID R. LOWRY IN SUPPORT OF IDAHO POWER
COMPANY'S BRIEF ON RECONSIDERATION REGARDING RELOCATION
REQUESTS FROM THIRD PARTIES upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Building Contractors Association of
Southwestern Idaho
Michael C. Creamer
GIVENS PURSLEY, LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
City of Nampa AND
Association of Canyon County Highway
Districts
Matthew A. Johnson
Davis F. VanderVelde
WHITE PETERSON GIGRAY
ROSSMAN NYE & NICHOLS, P.A.
5700 East Franklin Road, Suite 200
Nampa, Idaho 83687-7901
The Kroger Co.
Michael L. Kurtz
Kurt J. Boehm
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
Kevin Higgins
Energy Strategies, LLC
215 South State Street, Suite 200
Salt Lake City, Utah 84111
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X Email weIdon.stutzmanciuc.idaho.iov
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X Email mcccivensDursley.com
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X Email miohnsonwhitepeterson.com
dvandervelde(äwhiteDeterson .com
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X Email mkurtz(BKLIawfirm.com
kboehmBKLlawfirm.com
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X Email khiqqinsceneriystrat.com
AFFIDAVIT OF DAVID R. LOWRY IN SUPPORT OF IDAHO POWER COMPANY'S BRIEF
ON RECONSIDERATION REGARDING RELOCATION REQUESTS FROM THIRD PARTIES -3
Ada County Highway District
Scott D. Spears
Ada County Highway District
3775 Adams Street
Garden City, Idaho 83714
Merlyn W. Clark
D. John Ashby
HAWLEY TROXELL ENNIS &
HAWLEY, LLP
877 Main Street, Suite 1000
P.O. Box 1617
Boise, Idaho 83701-1617
Build Idaho Inc.
J. Frederick Mack
HOLLAND & HART LLP
U.S. Bank Plaza
101 South Capitol Boulevard, Suite 1400
P.O. Box 2527
Boise, Idaho 83701-2527
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X U.S. Mail
- Overnight Mail
FAX
X Email sspearsachd.ada.id.us
Hand Delivered
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FAX
X Email mclark(hawIeytroxeIl.com
iashbv(ãhawlevtroxelI.com
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FAX
X Email fmack(hol land hart. com
Kiniberly Towell)Executive Assistant
AFFIDAVIT OF DAVID R. LOWRY IN SUPPORT OF IDAHO POWER COMPANY'S BRIEF
ON RECONSIDERATION REGARDING RELOCATION REQUESTS FROM THIRD PARTIES -4
EXHIBIT A
]IDAHO POWER RELOCATIONS FROM ROAD RIGHTS-OF-WAY
FOR THIRD PARTIES
MCMILLAN/TEN-MILE INTERSECTION PROJECT - Meridian
Idaho Power Contact: Dave Lowry
Road(s) Involved: Intersection of McMillan and Ten-Mile Roads
Year of Work: 2008
Requesting Party: Bridgetower Development
Description of Work: Relocated overhead power lines underground in connection with intersection
widening.
MCMILLAN/LINDER INTERSECTION PROJECT - Meridian
Idaho Power Contact: Dave Lowry
Road(s) Involved: Intersection of McMillan and Linder Roads
Year of Work: 2008
Requesting Party: Brighton Corporation
Description of Work: Relocated overhead power lines underground in connection with intersection
widening.
USTICK/LINDER INTERSECTION - Meridian
Idaho Power Contact: Dave Lowry
Road(s) Involved: Intersection of Ustick and Linder Roads
Year of Work: 2007
Requesting Party: Brighton Corporation
Description of Work: Relocated overhead power lines underground in connection with intersection
widening.
ALPINE VILLAGE CONDOMINIUMS PROJECT - McCall
Idaho Power Contact: Mark Wood
Road(s) Involved: 3rd Street
Year of Work: 2007
Requesting Party: Alpine Village Company
Description of Work: Relocated approximately one block of overhead power line to underground in
connection with Alpine Village development.
McCALL THIRD STREET UNDERGROUND RELOCATION - McCall
Idaho Power Contact: Mark Wood
Road(s) Involved: 3rd Street
Year of Work: 2007
Requesting Party: City of McCall (from franchise monies)
Description of Work: Relocated approximately one block of overhead line to underground. City
installed curb, gutter and sidewalk.
TAMARACK RESORT PROJECT - Cascade
Idaho Power Contact: Mark Wood
Road(s) Involved: West Mountain Road
Year of Work: 2004
Requesting Party: Tamarack Resort
Description of Work: Relocated overhead to underground over 2300' of three-phase distribution
line and over 1900' of single-phase distribution line. Customer's own
improvement project.
EXHIBIT A
CITY OF McCALL GENERAL UNDERGROUNDING - McCall
Idaho Power Contact: Mark Wood
Road(s) Involved: Primarily 3rd Street and Lake Street
Year of Work: Ongoing
Requesting Party: Developer
Description of Work: New developments in these areas are generally required to install new curb,
gutter, and sidewalks, and relocate overhead power lines in the immediate
vicinity to underground.
LEGACY SUBDIVISION - Eagle
Idaho Power Contact: Roy Norton
Road(s) Involved: Floating Feather Road
Year of Work: 2007
Requesting Party: Idaho Development Services LLC
Description of Work: Customer paid to underground the primary distribution to serve Legacy
Subdivision in Eagle. The road was not widened - just relocation from
overhead to underground.
WEST JUNIOR HIGH SCHOOL - Boise
Idaho Power Contact: Roy Norton
Road(s) Involved: Victory Road
Year of Work: 2008
Requesting Party: Boise School District
Description of Work: School District paid to have the power line poles relocated into the new right-
of-way on Victory Road.
SOUTIIJIRIDGE SUBDIVISION - Meridian
Idaho Power Contact: Roy Norton
Road(s) Involved: Linder Road
Year of Work: 2010
Requesting Party: JLJ Enterprises, Inc.
Description of Work: Customer paid for the relocation of overhead power line to new road right-of-
way for new subdivision.
BATTERIES PLUS STORE - Nampa
Idaho Power Contact: Don Walz
Road(s) Involved: 16174 Midland Blvd.
Year of Work: 2012
Requesting Party: Batteries Plus
Description of Work: Remove two poles and relocate one pole within the road right-of-way for new
commercial building.
CITY OF KETCHUM - RIVER STREET RELOCATION OVERHEAD TO UNDERGROUND -
Ketchum
Idaho Power Contact: Cyndi Bradshaw
Road(s) Involved: 2nd Avenue
Year of Work: 2007
Requesting Party: City of Ketchum
Description of Work: Relocate existing overhead distribution line to underground.
2
EXHIBIT A
EVERGREEN CON DOMINIUMS - Ketchum
Idaho Power Contact: Cyndi Bradshaw
Road(s) Involved: River Street
Year of Work: 2007
Requesting Party: Evergreen Condominiums - Woodinville, Washington
Description of Work: Relocate existing overhead distribution line to underground.
INTERMOUNTAIN CONSTRUCTION - Ketchum
Idaho Power Contact: Cyndi Bradshaw
Road(s) Involved: North lS Avenue
Year of Work: 2007
Requesting Party: Intermountain Construction
Description of Work: Relocate existing overhead distribution line to underground.
MORNING SUN SUBDIVISION - Twin Falls
Idaho Power Contact: Brent Pollard
Road(s) Involved: Falls Ave E
Year of Work: 2007
Requesting Party: Morning Sun Subdivision
Description of Work: Relocate overhead line due to road widening in conjunction with new
development.
LDS CHURCH - Twin Falls
Idaho Power Contact: Brent Pollard
Road(s) Involved: Eastland Drive North
Year of Work: 2009
Requesting Party: City of Twin Falls/LDS Church
Description of Work: Underground existing power line at developer request in connection with road
widening and sewer line upgrade.
CANYON RIDGE HIGH SCHOOL - Twin Falls
Idaho Power Contact: Brent Pollard
Road(s) Involved: North College Road and Sparks Street
Year of Work: 2009
Requesting Party: Canyon Ridge High School
Description of Work: Bury existing overhead line and relocate underground transformers to
accommodate road widening in conjunction with new High School.
ST. PAUL'S CATHOLIC CHURCH - Nampa
Idaho Power Contact: Don Walz
Road(s) Involved: 510 W Roosevelt Ave.
Year of Work: 2012
Requesting Party: CN Company, for St. Paul's Catholic Church
Description of Work: Remove four poles within the road right-of-way for new church development.
COSSA SCHOOL - Wilder
Idaho Power Contact: Don Walz
Road(s) Involved: Penny Lane
Year of Work: 2010
Requesting Party: COSSA School
Description of Work: Remove five poles in road right-of-way and reroute power line; upgrade
single-phase power to three-phase power to serve new school.
3
EXHIBIT A
CENTENNIAL BAPTIST CHURCH - Caldwell
Idaho Power Contact: Don Walz
Road(s) Involved: 3625 Ustick Rd
Year of Work: 2008
Requesting Party: Centennial Baptist Church
Description of Work: Remove four poles and relocate six new poles for improvements in the road
right-of-way for new turn lane for new school.
MIDDLETON HIGH SCHOOL ROUNDABOUT - Middleton
Idaho Power Contact: Don Walz
Road(s) Involved: Emmett Road and Willis Road roundabout
Year of Work: 2010
Requesting Party: Beniton Construction Co.
Description of Work: Remove three distribution poles and install three new poles; remove one 138
KV structure and install one 138 KV structure for Middleton High School
project.
SCHNELL SUBDIVISION - Middleton
Idaho Power Contact: Don Walz
Road(s) Involved: Highland Drive
Year of Work: 2006
Requesting Party: Schnell Subdivision
Description of Work: Remove six poles and install seven poles for improvements in the road right-
of-way.
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