20211028Petition to Intervene.pdf

C. Tom Arkoosh,lSB No.2253
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: tom.arkoosh osh.com
Admin Copy: [e-mail]
Attorneys for Cox Communications
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF IDAHO POWER
COMPAI{'Y' S PETITION FOR
APPROVAL OF A CUSTOMER
SURCHARGE AND MODIFIED LINE
ROUTE CONFTGURATION FOR
CONSTRUCTION OF A NEW I38 KV
TRANSMISSION LTNE IN THE WOOD
RIVER VALLEY
Case No. IPC-E-21-25
COX COMMUNICATIONS'
PETITION TO INTERVENE
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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:
l. 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
COX COMMUNICATIONS' PETITION TO INTERVENE - Page I
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 maffer 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 caniage 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 pafi,
but instead will streamline resolution of concrete issues that the construction of the facilities
COX COMMUNICATIONS' PETITION TO INTERVENE -Page2
contemplated by the Application has placed before the Commission.
10. The name and address of the intervenor is:
Cox Communications
clo C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise,ID 83701
Telephone: [phone]
Facsimile: Q08)343-5456
Email: [e-mail]
Admin Copy : [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 286 day of October202l.
ARKOOSH LAW OFFICES
C. Tom Arkoosh
Attorney for Cox Communications
COX COMMUMCATIONS' PETITION TO INTERYENE - Page 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 28th day of October 2O2l,I served a true and correct
copy of the foregoing document(s) upon the following person(s), in the manner indicated:
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702
Idaho Power Company:
Donovan E. Walker
Idaho Power Company
PO Box 70
Boise,lD 83707
Blaine County:
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
Boise,ID 83701
Timothy K. Graves
Chief Deputy Prosecuting Attorney
219 First Avenue South, Suite 201
Hailey,ID 83333
Bradley Mullins
MW Analytics, Energy & Utilities
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COX COMMUNICATIONS' PETITION TO INTERVENE - Page 4
Kiki LcslieA. Tidwell:
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7MN. River Sheeq #1
Hailey,ID E3333 x
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C. TomArkoosh
COX COMMIINICATIONS' PETITION TO II{TER\IENE - Page 5