20170505Cherp Direct.pdf

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C. Tom Arkoosh, ISB No. 2253
ARKOOSH LAW OFFICES
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: [phone]
Email : [e-mail]
Attomeys for CoxCom, LLC
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR A CERTIFICATE OF
PUBLIC CONVENIENCE AND
NECESSITY TO CONTRUCT SYSTEM
IMPROVEMENTS FOR WOOD RIVER
VALLEY CUSTOMERS
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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Case No. IPC-E-16-28
COXCOM,LLC, D/B/A COX
DIRECT TESTIMONY
GUY CHERP
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I Q. Please state your name.
2 A. Guy Cherp.
3 Q. Where do you reside?
4 A. I currently reside in Sun Valley, Idaho.
5 Q. What is your educational background?
6 A. I have a B.A. in Economics and Environmental Conservation from the
7 University of Colorado.
8 Q. What is your work experience in communications?
9 A. My experience in communications is primarily with Cox. I have worked
l0 for Cox Communications, Inc., since 2002 in various management and leadership roles.
I I Prior to that, I worked for Cox Interactive Media, Inc., a former operating division of Cox
12 Enterprises, Inc., which was the online presence of Cox's local media properties, for five
l3 years in various management and leadership roles.
14 a. What is Cox Communications (hereinafter "Cox")?
15 A. Cox Communications is a broadband communications and entertainment
l6 company, providing advanced digital video, Internet, telephone and home security and
17 automation services over its own nationwide IP network. The third largest U.S. cable
18 company, Cox serves approximately six million residences and businesses. Cox Business,
19 a component of Cox Communications, is a facilities-based provider of voice, video and
20 data solutions for commercial customers.
2l a. What is your employment history with Cox?
CHERP, DI - I
CoxCom, LLC, dlbla Cox
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A. I have worked for various Cox Enterprises, Inc. (the parent company of
Cox Communication, Inc.) operating companies for almost 30 years.
a. What is your title with Cox?
A. Vice President and Market Leader.
a. What services does Cox provide in the Wood River Valley?
A. Cox provides both residential and business customers in the four
municipalities and surrounding areas in Blaine County with advanced digital video,
Intemet, telephone and home and business security and automation services. These Cox
services provide critical connectivity for a variety of sectors including residential,
business and government entities, schools, hospitals and health care providers.
In the Wood River Valley, Cox serves more than 10,000 subscribers. Our hybrid
fiber optic and coax network is the conduit through which we deliver a wide range of
advanced video and communications services. We continue to make the necessary
investments to ensure that the residents and businesses in our communities have an
entertainment and communications infrastructure to meet their needs today and in the
future.
Cox Communications plays an important role in supporting local economic development
in the Wood River Valley. Here are some specific examples:
o Cox serves four municipalities and surrounding areas in Blaine County with
entertainment and telecommunications services.
o Cox employs 22 full-time residents.
o Cox pays nearly $2 million in Idaho payroll taxes and employee wages annually.
CHERP, DI - 2
CoxCom, LLC, dlb/a Cox
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I o Cox pays more than $280,000 in municipal franchise fees annually in ldaho.
2 o Cox pays nearly $l million to Wood fuver Valley area contractors and vendors on
3 an annual basis.
4 o Over the past five years, Cox has invested more than $18 million in the
5 community, including new office facilities, a new Master Telecommunications
6 Center and network infrastructure.
7 o Cox provides nearly the entire Wood River area with state-of-the-art, broadband
8 technology using our fiber optic and coax network.
9 Q. Please describe the Cox's physical facilities in the Wood River Valley.
l0 A. Cox maintains a retail store, warehouse and office facility at340 Lewis
I I Street in Ketchum, Idaho. In addition, Cox's newly-renovated Master
12 Telecommunications Center (MTC) is located at 811 Warm Springs Road in Ketchum.
l3 The MTC location serves as both our connection receiving point and our central
14 distribution point to the entire Wood River Valley. The fiber link to our MTC location is
l5 critical to our ability to provide services in the Wood River Community.
16 a. What are your duties and responsibilities with regard to the Cox system in
17 the Wood River Valley?
18 A. I oversee all aspects of Cox Communications' operations in the Wood
19 River Valley.
20 a. Please describe the interrelationship between the services provided by Cox
2l in the Wood River Valley and the reliability of electrical supply.
CHERP, DI - 3
CoxCom, LLC, d/b/a Cox
1 A. Electrical power reliability is critically important to our operation. We
2 count on it to power our facilities and our network, enabling us to provide E911-
3 compliant lifeline connections; connections that support daily business operations for our
4 commercial customers; and critical connections to the world for all of us.
5 Q. By what authority does Cox operate in the Wood River Valley?
6 A. Cox has held a state-issued video franchise agreement with a certificate to
7 operate in the Wood River Valley since July 2011. Further, we have a contract with
8 Idaho Power Company to attach facilities to their poles that are at issue in this matter.
9 This contract refines our rights to attach to these poles as provided in state and federal
l0 law.
I I a. Please describe the business relationship between Cox and Idaho Power
12 Company.
13 A. Cox is a significant Idaho Power customer, using their services to power
14 our entire network and facilities. Additionally, as indicated, Cox has a pole attachment
l5 agreement with Idaho Power, whereby we compensate Idaho Power for the right to attach
16 our equipment to their poles.
17 a. Please describe the physical relationship between the Cox facilities and the
l8 Idaho Power facilities in the Wood River Valley.
19 A. Cox's equipment is attached to Idaho Power's poles throughout the service
20 area. Our transport and distribution networks attach to the route of the poles under
2l consideration for Idaho Power's redundancy transmission line route from Hailey to
22 Ketchum/Sun Valley.
CHERP, DI - 4
CoxCom, LLC, d/b/a Cox
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Have you read the Application in this maffer?
Yes
What effect do you anticipate denial of the Application will have upon
Cox and its customers?
A. The status quo will be maintained with no impact to Cox. Cox will
continue to be a tenant on the existing Idaho Power's Highway 75 pole run and service to
our customers will not be interrupted.
a. What effect do you anticipate an order granting the Application will have
upon Cox and its customers?
A. The impact to Cox and its customers will depend on the form of the final
order. If it authorizes Idaho Power to replace its current distribution poles in order to
accommodate transmission facilities, but the pole height is restricted to such a degree that
there is no room for telecommunications cabling, then Cox will be required to either seek
permission to install its own separate poles or bury our current aerial cabling. Either
comes at tremendous added cost and would have the effect of redirecting capital dollars
otherwise vital to continuous and ongoing upgrades to our network. This particular
option would have the effect of treating Cox in a discriminatory manner, and under state
law Cox would request the intervenors favoring this option be ordered to reimburse Cox
for the difference in cost between aerial and underground placement. Maintenance and
reliability are very realistic concerns if Cox's communication facilities are forced
underground. These attributes become more difficult to sustain underground. Access for
maintenance becomes a special concern for underground facilities. Because we must
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CoxCom, LLC, d/b/a Cox
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I remain E911 compliant, such a massive alteration to our system and its consequences,
2 both known and unknown, incite some apprehension.
3 In the alternative, if the final order authorizes poles that also can accommodate
4 telecommunications facilities then it would simply be a matter of Cox coordinating the
5 transfer of our existing aerial lines to the new poles upon conclusion of installation.
6 Under formula adopted by the FCC and recognized by the Idaho Public Utilities
7 Commission, Cox would continue to compensate Idaho Power for the right to occupy
8 these poles, which is a budgeted and ongoing standard operational expense.
9 a. If the Idaho Public Utilities Commission ("PUC") grants the Application
l0 in a modified form by ordering Idaho Power's redundant transmission facility between
I I the Hailey and Ketchum substations be buried underground, what effect do you anticipate
12 that order will have on Cox and its customers?
13 A. In this instance Cox would be required to either seek permission to install
14 our own poles or convert our current aerial cabling to underground. Either option would
l5 be very expensive and would divert scarce capital dollars away from ongoing network
l6 upgrades and ultimately impacting end customer experience and value.
L7 a. What is Cox's preference in this matter?
l8 A. As indicated, we are reliant upon the reliable provision of electricity to
19 service our customers and must defer to Idaho Power and the Commission to achieve that
20 level of performance. If the Commission determines this will be accomplished with the
2l current system, we are content with our current iurangement with Idaho Power. If,
22 however, the Commission grants the certificate, we request that it assure the ultimate
CHERP, DI - 6
CoxCom, LLC, d/bla Cox
I physical facilities authorized can accommodate attachment of our equipment to the new
2 poles.
3 Q. Does this conclude your direct testimony?
4 A. Yes.
CHERP, DI .7
CoxCom, LLC, d/b/a Cox
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ATTESTATION OF TESTIMONY
STATE OF rDAHO )
)ss.
County of Blaine )
I, Guy Cherp, having been duly sworn to testify truthfully, and based upon my personal
knowledge, state the following:
I am employed by CoxCom, LLC, dlbla Cox, as the Vice President and Market Leader
and am competent to be a witness in this proceeding.
I declare under penalty of perjury of the laws of the state of Idaho that the foregoing pre-
filed testimony is true and correct to the best of my information and belief.
DATED this \\ day of [pr;1 .2017.
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Guy Cherp
SUBSCRIBED AND SWORN to before me this
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Residing at; Lru-L 1&
My commission expirest @
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CoxCom, LLC, dlbla Cox
gOTApp.
Puu-rG
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 5th day of May,2017,l served a true and correct copy of
the foregoing document(s) upon the following person(s), in the manner indicated:
Orieinal and # cooies to:
Diane M. Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702
Electronic copies to:
Donovan E. Walker
Tim Tatum
Idaho Power Company
PO Box 70
Boise, ID 83707
Daphne Huang
Camille Christen
Deputy Attomeys General
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, lD 83720
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St.
PO Box 7218
Boise, ID 83702
Kiki Leslie A. Tidwell
300 Let'er Buck Road
Hailey, ID 83333
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diane.hanian@puc. idaho. sov
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x
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dwalker@idahopower. com
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cami lle.christen@puc. idaho. gov
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peter@richardsonadam s. com
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com
CHERP, DI - 9
CoxCom, LLC, d/b/a Cox
Kelsey Jae Nunez
Kelsey Jae Nunez LLC
920 N. Clover Dr.
Boise,ID 83703
Zack Waterman
Director, Idaho Sierra Club
503 W. Franklin St.
Boise, lD 83702
Michael Heckler
3606 N. Prospect Way
Garden City,ID 83714
Benjamin J. Otto
Idaho Conservation League
710 N. Sixth Street
Boise, ID 83702
Laura Midgley
231Yalley Club Drive
Hailey, ID 83333
Matthew A. Johnson
Wm. F. Gigray
White Peterson Gigray & Nichols, PA
5700 E. Franklin Rd., Suite 200
Nampa, ID 83687
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kelsev@kelseyi aenunez.com
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zack.waterman@sierracl ub. org
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[e-mail]
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X E-mail midsley22l 5 @emai l. com
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botto@ idahoconservation. org
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mj ohnson@whitepeterson. com
CHERP, DI - IO
CoxCom, LLC, d/b/a Cox
Gregory M. Adams
Richardson Adams, PLLC
515 N. 27n St.
P.O. Box 7218
Boise, lD 83702 x
C. Tom Arkoosh
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ere g@richardsonadams. com
CHERP,DI- II
CoxCom, LLC, d/bla Cox