20020925Pacificorp's Response.pdf

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T&D Infrastrncture Management
Distribution
825 E. Holladay, Suite 230
Portland, Oregon 97232
UTilITIES COJ-jl'lISSION
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September 20, 2002
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
Re:Case No. GNR-02-
Response to Staff Proposal Dated September 6 2002
Dear Mr. Stutzman:
The following material was prepared in response to your request dated September 6
2002, seeking a response to Staffs revision to its proposal.
As stated in PacifiCorp s letter to Mr. Stutzman dated Augu~t 7, 2002, PacifiCorp agrees
conceptually with the proposal made by Idaho Power for a new rate methodology
because this approach should allow for more appropriate recovery of the total cost of pole
ownership from all of the parties that receive the benefits. Staffs proposed approach
differs from the approach proposed by Idaho Power because it reduces the costs allocated
to pole users other than the pole owner. Moreover, Staffs approach does so without
providing substantial cost-causation justification, citing only an interest in obtaining a
result closer to that obtained from the formula applied in Benewah. Thus, PacifiCorp
does not endorse Staffs approach.
PacifiCorp does not oppose an evidentiary hearing in this case.
Very truly yours
Corey Fitz Gerald, Manager
T &D Infrastructure Management
cc: Parties of Record