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Home My WebLink About20051021Dairymen, Milk Producers.pdfGIVE \!rr ,~ tJ.J t. l1 t. L ;t rn SLEy'"LLP ~ ,..'" ~ ry~;~ 1)0 n1 / L' tH- .,.. R vL - E-oS -0 -"' LAW FFI Cl ; , , 'v.- 601W.BannockStre!;Jt ~\ ','~-\~: :c:' r'1t"l tSSlOHPO Box 2720. Boise, Iga~ola31;()1 i \, " , ) v TELEPHONE; 208 388.1200 FACSIMILE: 208 388.1300 WEBSITE: WINW.givenspursley.com Gary G. Allen Kristen A. Alwood Kelly T. Barbour Christopher J. Beeson William C. Cole Michael C. Creamer Thomas E. Dvorak Roy Lewis Eiguren Timothy p. Fearnside Jeffrey C. Fereday Melissa A. Finocchio Steven j. Hippler Karl T. Klein Debora K. Krislei1sen Anne C. Kunkel October 21,2005 Donald L. Howell, II~ Esq. Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington Street Boise, Idaho 83720 Re:Comlnents on Stray Voltage Rules Docket No. 31-6101-0501 Dear Don: Jeremy G. Ladle Franklin G. Lee David R. Lombardi Emily A. MacMaster John M. Marshall Kenneth R. McClure Kelly Greene McConnell Cynthia A. Melillo Christopher H. Meyer L Edward Miller Patrick J. Miller Judson B. MCJntgomery Angela K. Nelson Deborah E. Nelson W. Hugh O'Riordan, LL. Kenneth L. Pursley BradleyV. Sneed H. Barton Thomas. LLM. J. Will Va, Conley E. Ward Robert B. White Raymond D. Givens RETIRED James A. McClure RETIRED /Jcensed In California Thank you for distributing the comlnents Idaho Power filed with you concerning the proposed stray voltage rules. We appreciate the opportunity to review and respond to them. For your record, the only comtnents we have seen frall1 Idaho Po'wer are from Paul E. Ortmann, P.E. (undated) \vhich you forwarded to itlterested parties on October 15, 2005. Further for the record, we have reviewed the Staff s proposed changes which were distributed yesterday. Finally, by way of preliminary nlatters, this letter is submitted on behalf of the Idaho Dairynlens' Association and the Milk Producers of Idaho. Addressing Mr. Ortnlann s COlll1nents first, we have no issues with the recomnlendations he has identified as Recolnmendations 1 and 2 or ,vith the suggested rule changes associated with those reconlmendations. They appear to be appropriate modifications to the proposed rules. ecommendation 3 also appears to be appropriate although we believe the rule change associated with it (Rule 071.02.e) would benefIt frain clarification. First, we believe that a limited evaluation should be conducted only with the consent of the dairy. That consent should be evidenced in writing both to avoid confusion and to clarify that the utility will not conduct testing on the dairy premises without the prior consent of the dairy. The language proposed by Staff for that provision incorporates the requirelnent of written consent in an appropriate fashion. We would also suggest that the writing contain Don Howell October 21,2005 Page 2 an explanation of the reasons for conducting a liulited evaluation so the dairy 1uay be fully inforn1ed of the reasons the utility believes a full evaluation is not necessary. The following language for Rule 071.03 (as numbered in the Staffs draft) would satisfactorily address our concerns: 03 Suspended or Limited Testing. With the written agreCll1ent of both the utility and the dairy producer, a stray voltage investigation ll1ay be suspended at any point in the investigation. With the written agreeInent of both the utility and the dairy producer, the utility may employ a litnited set of tests or tueasurements on a dairy as part of an intentionally lin1ited evaluation. If the utility PIQJJoses to suspend a strayovo investigation or to conduct a linlited evaluation, tts reasons for doing so shall be set forth in the written agreement between the ll1iliJ;y ancLthe dairy QmQucer. We do not agree with that portion of Recolumcndation 4 which would reduce the primary profile test fron1 three quarters to one half mile. We believe the requirement for testing within three quarters of a mile from the primary service point for the dairy is appropriate to ensure that issues on the distribution line close to the dairy are identified and appropriately relnedied. Weare not sure what would make it "irnpra.cticaP~ to "test starting at one end of the the distribution systelll and working toward the other end... and therefore are concerned about the proposed addition to Rule 075.02.a of the phrase To the extent practicaL,.." Unless there is substantiation in the rulen1aking record for this modification we would suggest that it not be included. Other than the proposed lTIoditication to Rule 071,03 set forth above we have no con1ments on the Staffs proposals you emaiIed yesterday other than to say that they are satisfactory and appropriate. We thank you for the opportunity to submit these comments to you for your consideration. i?fw~ Kenneth R. McClure co:Brent Olmstead Bob Naerebout ex Blackburn