20030312Petition for Stay.pdf

BARTON L. KLINE ISB #1526
MONICA MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
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UTlLri 1ES CO !SSION
Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
INVESTIGATION OF TIME-OF-USE
PRICING FOR IDAHO POWER
RESIDENTIAL CUSTOMERS.
IDAHO POWER COMPANY'
PETITION FOR STAY
CASE NO. IPC-02-
Idaho Power Company (hereinafter referred to as "Idaho Power" or "the
Company ), Petitioner herein , pursuant to RP 324 , respectfully petitions the
Commission to issue its Order staying the requirement in Order No. 29196 that by
March 20 2003, Idaho Power Company submit a plan to replace all of its existing retail
revenue meters with an automated meter reading (AMR) system by the end of 2004.
This Petition is based on the following:
IDAHO POWER COMPANY'S PETITION FOR STAY, Page
Confirmation by the Commission that Order No. 29196 is a final
order as set forth in the Company s Petition For Confirmation filed concurrently with this
Petition For Stay.
In Order No. 29196 dated February 21 2003, the Commission
ordered Idaho Power to immediately begin replacing the Company s existing revenue
metering equipment with an automated meter reading system with the replacement
process to be completed by the end of 2004. In Order No. 29196, the Commission also
ordered "that no later than March 20, 2003, Idaho Power Company submit a plan to
replace the current meters of Idaho Power customers with advanced meters as
described in detail above.
Because there were no hearings conducted in this case , Idaho
Power has been unable to express its concerns relating to the replacement of the
Company s existing revenue metering equipment and the installation of an AMR
system. Idaho Power has outlined those concerns in the Petition For Reconsideration
which the Company has filed concurrently with this Request For Stay. The Petition For
Reconsideration identifies numerous separate issues relating to the deployment of AMR
that Idaho Power believes the Commission should address in a formal hearing.
Conducting a hearing will give all parties an opportunity to present facts and evidence
on the record for consideration by the Commission.
Preparing the plan required by Order No. 29196 to replace the
Company s existing metering equipment with an AMR system will require the
expenditure of substantial time , effort and resources. In addition, many of the issues
the Company has identified in its Petition For Reconsideration are issues that, by
IDAHO POWER COMPANY'S PETITION FOR STAY, Page 2
necessity, will be addressed in any implementation plan prepared by Idaho Power.
Recognizing that the Commission initially has 28 days within which to decide whether or
not it will grant reconsideration, and up to 17 weeks to issue an order on
reconsideration , it is clear that, unless the Commission suspends Idaho Power
obligation to file an implementation plan by March 20, 2003, Idaho Power could be
required to file the plan to implement an AMR system before the Commission issues a
final order in this proceeding. Idaho Power requests an opportunity to address its
concerns with the AMR deployment described in Order No. 29196 prior to being
required to present any implementation plan. In short , the Company is urging the
Commission to stay its order pending reconsideration before the Company expends the
substantial time , effort and resources required to prepare the AMR implementation plan
required by Order No. 29196.
Idaho Power hereby requests that the Commission consider this
Petition For Stay on an expedited basis pursuant to RP 256 and issue its order
suspending Idaho Power s obligation to file an AMR implementation plan by March 20
2003, so that Idaho Power can avoid expending the substantial effort required to
develop a plan to implement the AMR system prior to the time that a full review of the
issues relating to an AMR system can take place in a hearing before the Commission.
Counsel for Idaho Power Company has personally contacted Ms.
Nordstrom of the IPUC Staff, Mr. Eddie of Advocates for the West , and Mr. Delurey from
DRAM and advised them that the Company had filed this Petition and is requesting an
expedited order.
IDAHO POWER COMPANY'S PETITION FOR STAY, Page 3
Respectfully submitted this 12th day of March 2003.
070( J:j
BARTON L. KLI N E
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S PETITION FOR STAY, Page 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 12th day of March, 2003, I served a true
and correct copy of the within and foregoing IDAHO POWER COMPANY'S PETITION
FOR STAY upon the following named parties by the method indicated below, and
addressed to the following:
Lisa Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
---1L Hand Delivered
S. Mail
Overnight Mail
FAX
William M. Eddie
Land & Water Fund of the Rockies
O. Box 1612
Boise, Idaho 83701
---1L
Hand Delivered
S. Mail
Overnight Mail
FAX---1L
Dan Delurey, Executive Director
Demand Response and Advanced
Metering Coalition (DRAM)
O. Box 33957
Washington, D.C. 20033
Hand Delivered
S. Mail
Overnight Mail
FAX
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BARTON L. KLINE
CERTIFICATE OF SERVICE