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Home My WebLink About20040116Comments of PacifiCorp.pdfDale G. Rasmussen OSB #88292 PacifiCorp 825 NE Multnomah Suite 1800 Portland OR 97232 Telephone: (503) 813-5194Fax: (503) 813-7252 Attorney for PacifiCorp f?t="HI.- ... ,- r:"ILED ~.. 2notl JM! 16 Ari 9: 3~ I;') i UdL!C UTILIT iES CO~'ir"ilSSIOH BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION FILED BY) IDAHO POWER COMPANY FOR APPROVAL OF MODIFICATIONS TO THE SECURITY PROVISIONS REQUIRED TO BE INCLUDED IN POWER PURCHASE AGREEMENTS BETWEEN ELECTRIC UTILITIES (IDAHO POWER, A VISTA CORPORATION DBA A VISTA UTILITIES, AND PACIFICORP DBA UTAH POWER & LIGHT COMPANY) AND PURPA QUALIFYING FACILITIES (QFs) CASE NOS. IPC-03- A VU-03- PAC-03- PACIFICO RP' S COMMENTS IN SUPPORT OF THE PETITION OF IDAHO POWER COMPANY COMES NOW PacifiCorp ("PacifiCorp" or the "Company ) and, pursuant to RP , hereby provides comments in support of the petition filed November 5 2003, by Idaho Power Company ("Idaho Power ) with the Idaho Public Utilities Commission (the Commission ) for issuance of an Order authorizing Idaho Power to accept modified insurance and lien rights as satisfactory risk mitigation measures in agreements between Idaho Power and co-generators and small power producers ("CSPPs ) that contain levelized rates (the "Petition P ACIFICORP' S COMMENTS - 1 PacifiCorp is a retail electrical utility with service territories in the States of California, Idaho, Oregon, Utah, Washington and Wyoming. PacifiCorp is under contract with some 13 separate CSPPs located in Idaho, as well as with numerous other CSPPs located throughout its other service territories. Although all but one of PacifiCorp s contracts with CSPPs located in Idaho were entered into prior to the effective date of Commission Order 21692, as these contracts terminate the Company will be faced with many of the same issues addressed in the Petition. The focus of the Petition is narrow. It does not address all of the myriad issues that must be dealt with in the context of analyzing whether a contract with a particular CSPP adequately protects the interests of the Company and of its ratepayers. Accordingly, PacifiCorp s Comments are not intended, and should not be considered, a comprehensive statement of position on the issue of what security measures may be appropriate in a particular contract. The Company expressly reserves the right to address specific terms in its negotiations with CSPPs and with the Commission in future proceedings associated with such contracts. P ACIFICORP' S COMMENTS - 2 III Subject to the foregoing, the Company generally supports the position taken by Idaho Power in the Petition. However, the Company feels that in order to adequately protect its interests and those of its shareholders without unduly burdening CSPPs desiring to enter into contracts for the sale of power, it is important to add the following classes of insurance coverage to those set out in the Petition and its Exhibits: First Automotive Liability coverage with limits of $1 Million/incident; and Second, Worker Compensation coverage with limits of $1 Million/incident. Service of pleadings, exhibits, orders and other documents relating to this proceeding should be served on the following: Dale G. Rasmussen Associate General Counsel PacifiCorp 825 NE Multnomah Suite 1800 Portland OR 97232 dale.rasmussen~pacificorp. com Colin Persichetti Director, Marketing & Trading PacifiCorp 825 NE Multnomah Suite 600 Portland OR 97232 co lin. persichetti(2V,pacifi corp. com Respectfully submitted this 15th day of January, 2004 -'-"-'-- / ..-' ;;::,', , --r5~le-G ~ / ";, Attomey for PaclfiCorp P ACIFICORP'S COMMENTS - 3 CERTIFICATE OF SERVICE Docket Nos. PAC-03-, IPC-03-, A VU-03- I hereby certify that I have this day caused the foregoing document to be served on the following parties via US Mail. H. Douglas Young Avista Corp. PO Box 3727 Spokane, W A 99220-3727 R. Blair Strong Paine Hamblen Et Al 717 W. Sprague Ave. Spokane, W A 99204 Barton L. Kline Monica B. Moen Idaho Power Company PO Box 70 Boise, ID 83707-0070 Randy Allphin Idaho Power Company PO Box 70 Boise, ID 83707-0070 Mark Widmer PacifiCorp 825 NE Multnomah Portland, OR 97232 Dated this 15th day of January, 2004. JI4 1Ju Mark Tucker Regulatory Filing Coordinator