20211102Amended Petition to Intervene.pdf

COX COMMUNICATIONS’ AMENDED PETITION TO INTERVENE – Page 1
C. Tom Arkoosh, ISB No. 2253ARKOOSH LAW OFFICES913 W. River Street, Suite 450P.O. Box 2900Boise, ID 83701Telephone: [phone]Facsimile: [phone]Email: [e-mail] Copy: [e-mail]
Attorneys for Cox Communications
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY’S PETITION FOR APPROVAL OF A CUSTOMER SURCHARGE AND MODIFIED LINE ROUTE CONFIGURATION FOR CONSTRUCTION OF A NEW 138 kV TRANSMISSION LINE IN THE WOOD RIVER VALLEY
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Case No. IPC-E-21-25
COX COMMUNICATIONS’ AMENDED PETITION TO INTERVENE
COMES NOW Cox Communications (“Cox”), by and through its counsel of record,
C.Tom Arkoosh of Arkoosh Law Offices, and hereby petitions to intervene in the above-
captioned matter pursuant to the Rules of Procedure of the Idaho Public Utilities Commission
(IDAPA 31.01.01.071, et seq.) and the Commission’s Order No. 35194, Notice of Application,
and Notice of Intervention Deadline, issued on October 12, 2021.
In support of this Petition, Cox provides as follows:
1. Cox is duly authorized to do and is doing business in the State of Idaho.
2.Cox is engaged in the commercial cable television service and
telecommunications business as a service corporation.
3. Cox has a direct and substantial interest in the above-captioned matter. Currently,
Cox provides digital services to the north portion of Blaine County in part via hardware currently
RECEIVED
2021 NOV -2 PM 4:29
IDAHO PUBLIC
UTILITIES COMMISSION
COX COMMUNICATIONS’ AMENDED PETITION TO INTERVENE – Page 2
attached to Idaho Power’s present transmission facilities serving the north portion of Blaine
County and wishes to attach hardware to the transmission line proposed in the above-entitled
case.
4. Cox desires to assure that there will be continued room for their equipment on any
new construction resulting from the requested Certificate of Public Convenience and Necessity
for the Wood River Valley. The exclusion of Cox from the pending proceedings could result in
extreme and substantial hardship, needless expense, and redundant proceedings and processes.
5. Intervention by Cox will not unduly broaden these issues in this matter because
manner of construction, equipment used therefor, and placement of equipment are directly before
the Commission in the pending Application on file.
6. Intervention by Cox is in the public interest because settlement of the issues
regarding placement and cost of the new facilities contemplated by the prayed-for Certificate of
Public Convenience and Necessity are currently directly before the Commission in the pending
Application.
7. Intervention by Cox will not cause delay or prejudice to the parties in the above-
captioned matter because the issues of interest to Cox are currently squarely before the
Commission.
8. Intervention by Cox is appropriate to allow Cox to present to the Commission the
perspective regarding the most effective and efficient means and manner to accommodate the
continued carriage of telecommunication facilities on the new transmission line contemplated by
the Application.
9. Cox represents its intervention in the pending matter will not prejudice any party,
but instead will streamline resolution of concrete issues that the construction of the facilities
COX COMMUNICATIONS’ AMENDED PETITION TO INTERVENE – Page 3
contemplated by the Application has placed before the Commission.
10. The name and address of the intervenor is:
Cox Communications c/o C. Tom Arkoosh Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900 Boise, ID 83701 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Admin Copy: [e-mail] Electronic copies only to: Mark DiNunzio [e-mail]
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided as noted above.
Wherefore, Cox respectfully prays the Commission issue its order allowing Cox’s
intervention in the above-entitled matter.
DATED this 2nd day of November 2021.
ARKOOSH LAW OFFICES
_______________________________ C. Tom Arkoosh
Attorney for Cox Communications
COX COMMUNICATIONS’ AMENDED PETITION TO INTERVENE – Page 4
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 2nd day of November 2021, I served a true and correct
copy of the foregoing document(s) upon the following person(s), in the manner indicated:
Idaho Public Utilities Commission 472 W. Washington Boise, ID 83702
X__

-mail:
[e-mail]
Idaho Power Company:
Donovan E. Walker
Idaho Power Company PO Box 70 Boise, ID 83707

_X__

-mail: [e-mail]
Blaine County: Ronald L. Williams Williams Bradbury, P.C.
P.O. Box 388
Boise, ID 83701

X__
simile
-mail:
williamsbradbury.com
Chief Deputy Prosecuting Attorney
219 First Avenue South, Suite 201
Hailey, ID 83333 X__
ernight Courier

-mail: id.us
MW Analytics, Energy & Utilities
Electronic Copies Only
______
____________ X__
-mail:
[e-mail]
COX COMMUNICATIONS’ AMENDED PETITION TO INTERVENE – Page 5

Kiki Leslie A. Tidwell:
Kiki Leslie A. Tedwell
704 N. River Street, #1 Hailey, ID 83333 X__

-mail:
_________________________________ C. Tom Arkoosh