20181003Amended Application.pdf

October 3, 2018
VIA OVERNIGHT DELIVERY
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702
Re:CASE NO. PAC-E.18.06
IN THE MATTER OF THE APPLICATION FOR APPROVAL OF THE
CUSTOMER TRANSFER AGREEMENT BETWEEN ROCKY MOUNTAIN
POWER AIID THE CITY OF IDAHO FALLS
Dear Ms. Hanian
Enclosed for filing in the above mentioned matter are an original and seven (7) copies of
Rocky Mountain Power and the city of Idaho Fall's Amended Joint Application for approval
of the transfer of electric service to Century Link and Cable One along Holmes Drive as
described in this Application.
Very truly yours,
ROCKY MOUNTAIN
EP,Iy,E^"n",,
"^-D
Vice President, Regulation
Enclosures
RECEIVED
2SlBOCI:3'AHll:21
1407 W. North Temple, Suite 330
Salt Lake City, Utah 8416
LIU
,il-rsl0N
Daniel E. Solander (lSB# 8931)
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone: [phone]
Email : daniel. solander@fracifi corp.com
Attorneyfor Roclcy Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION FOR APPROVAL OF
TIIE CUSTOMER TRANSFER
AGREEMENT BETWEEN ROCKY
MOUNTAIN POWER AIID THE CITY
OF IDAHO FALLS
AMENDED APPLICATION OF
ROCKY MOLINTATN POWER
CASE NO. PAC-E.18.06
AMENDED APPLICATION OF
ROCKY MOUNTAIN POWER
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Rocky Mountain Power hereby submits an amended application for approval of the
Customer Transfer Agreement ("Agreement") between Rocky Mountain Power ("Company")
and the City of Idaho Falls ("City"). The Company's original Application in this docket
incorrectly included a caption that referenced an asset transfer, and also incorrectly referenced
r.c $ 6l-328.
Rocky Mountain Power, a division of PacifiCorp, pursuant to provisions of the Electric
Stabilization Act, I.C. $ 6l-333, hereby makes application to the Idaho Public Utilities
Commission ("Commission") for approval of a customer transfer agreement which transfers
two small customers from the Company to ldaho Falls. This Agreement provides for Idaho
Falls to supply electric service to locations associated with the poles being relocated at Holmes
Drive to accommodate a road widening project in Idaho Falls, Bonneville County, as more
particularly described below. In support of this Application, Rocky Mountain Power states as
follows:
Page I
l. Rocky Mountain Power, a division of PacifiCorp, ah Oregon Corporation,
whose address is 1407 West North Temple, Suite 320 Salt Lake City, Utah 84116, is authorized
to do and is doing business in the state of ldaho. The Company provides retail electric service
to approximately 75,000 customers in the state and is subject to the jurisdiction of the
Commission. The Company's retail certificated service territory encompasses portions of
Fremont, Madison, Teton, Clark, Jefferson, Lemhi, Oneida, Bannock, Franklin, Caribou,
Butte, Bingham, Bear Lake and Bonneville counties. Rocky Mountain Power is a public utility
in the state pursuant to Idaho Code $ 6l-129.
2. Idaho Falls, which is located in Bonneville County, owns and operates an
electric power system within the municipal boundaries of the city for the convenience of its
citizens. The City's municipal service territory is surrounded by Rocky Mountain Power's
service territory. The Company currently provides electric service to one or more electric
customers located within the boundaries of the City and the City provides service to one or
more customers within the Company's service territory.
I. BACKGROUND
3. Rocky Mountain Power and the City have been discussing the relocation of the
Company's facilities within the road widening project for South Holmes, located
approximately five hundred feet south of Township/49th South and extending one-half mile to
the south. On the west is Avalon Development (formerly Sunterra) and the Cornerstone
Assembly of God development. On the east are Belmont Estates 2 and Belmont Estates l.
4. On May 23,2018, the City served Rocky Mountain Power with a Notice and
Order to Vacate Construction Zone. Rocky Mountain Power and the City continued
negotiations regarding the relocation until June 13,2018, when the City filed a Verified
AMENDED APPLICATION OF
ROCKY MOLTNTAIN POWER
Page2
Complaint in the Seventh District Court alleging Trespass.
5. The Company agreed to relocate the facilities on June 14, 2018, and the
facilities have been de-energized and removed. Attached to the poles that are being relocated
are two small communications facilities owned and maintained by Century Link and Cable
One that receive service from Rocky Mountain Power, and are now being served by temporary
facilities. The City has agreed to serve these customers using its new facilities in the area. The
customers have no objection to being served by the City going forward. There are no Rocky
Mountain Power facilities that need to be transferred to the City in order for the City to serve
the customers.
6. Because the load and revenue associated with the service to the communications
facilities are minimal, the Company and the City have agreed to transfer service at no cost to
any party.
II. REQUEST FOR SERVICE TRANSFER
7. Rocky Mountain Power and the city of Idaho Falls hereby jointly petition the
Commission for approval of the transfer of electric service to Century Link and Cable One,
wherein Idaho Falls agrees to serve the load of the customers.
III. COMMUNICATION
8. Communications regarding this Application should be addressed to:
If to Rocky Mountain Power:
Ted Weston
Daniel E. Solander
1407 W. North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone : [phone]
Fax: [phone]
Email : [e-mail]
daniel.solander@nacifi com.com
AMENDED APPLICATION OF
ROCKY MOUNTATN POWER
Page 3
If to the City of Idaho Falls:
Idaho Falls City Power
Jackie Flowers
140 South Capital Avenue
Box50220
Idaho Falls, Idaho 83405
In addition, the Company respectfully requests that all data requests regarding this matter be
addressed to one or more of the following:
IV. MODIFIED PROCEDURE
9. The Company believes thata hearing is not necessary to consider the issues
presented herein and respectfully requests that this Application be processed under Modified
Procedure; i.e., by written submissions rather than by hearing. RP 201 et seq.If, however, the
Commission determines that a technical hearing is required, the Company stands ready for
immediate consideration of its Application and will present its testimony to support the
Application in such hearing.
V. CONCLUSION
WHEREFORE, Rocky Mountain Power and the city of Idaho Falls respectfully request
that the Commission: l) process this Application under Modified Procedure; 2) issue a final
order authorizingthe transfer of electric service for the customers described in Exhibit A to the
Agreement between Rocky Mountain Power and the city of Idaho Falls.
By e-mail (preferred)
By regular mail
AMENDED APPLICATION OF
ROCKY MOI.INTATN POWER
datarequest@pacifi corp.com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
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DATED this 3'd day of October, 2018
Respectfully submitted,
By \
Daniel E. Solander
Attorney for Rocky Mountain Power
AMENDED APPLICATION OF
ROCKY MOUNTAIN POWER
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