20091221Motion to Amend Application.pdf

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BARTON L. KLINE
Lead Counsel
bklinetmidahopower.com
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An IDACORP Company
December 21 , 2009
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-09-31
IN THE MA TTER OF THE APPLICA TlON OF IDAHO POWER COMPANY
FOR AUTHORITY TO SELL TO RAFT RIVER RURAL ELECTRIC
COOPERA TlVE, INC., CERTAIN ELECTRIC DISTRIBUTION FACILITIES
CURRENTL Y OWNED BY IDAHO POWER COMPANY
Dear Ms. Jewell:
Enclosed please find for filing an original and seven (7) copies of Idaho Power
Company's Motion to Amend Application in the above matter.
ve74. u.iy yours,(.fu~
Barton L. Kline
BLK:csb
Enclosures
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, 10 83702
BARTON L. KLINE (ISB No. 1526)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
P.O. Box 70
1221 West Idaho Street
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
bkline(áidahopower.com
Inordstrom(áidahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
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2009 DEC 2 i PM 3: 57
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO SELL TO RAFT RIVER
RURAL ELECTRIC COOPERATIVE, INC.,
CERTAIN ELECTRIC DISTRIBUTION
FACILITIES CURRENTLY OWNED BY
IDAHO POWER COMPANY.
)
) CASE NO. IPC-E-09-31
)
) MOTION TO AMEND
) APPLICATION
)
)
)
Idaho Power Company ("Idaho Power" or "the Company") filed an Application on
November 10, 2009, in which it requested authority from the Commission, pursuant to
Idaho Code § 61-328 and RP 52, to sell to Raft River Rural Electric Cooperative, Inc. ("Raft
Rivet') certain electrical distribution facilities and appurtenant rights-of-way owned by Idaho
Power in southern Twin Falls County, Idaho. In its Application, the Company advised that
it estimated that the sales price for the facilities, based on the net book value, would be
approximately $72,000.00, including a tax gross up. (Application, p. 3.) Upon further
MOTION TO AMEND APPLICATION - 1
review of this transaction by the Company's Delivery business unit, it has been determined
that it is extremely unlikely that there wil be any income tax liabilty created by this
transaction and, as a result, it is unnecessary for the Company to require a tax gross up to
fairly price the facilties to be sold. As a result, the sales price to Raft River is now
estimated to be approximately $44,000.00 rather than the $72,000.00 set out in the
Application. Documentation showing the derivation of the $44,000.00 amount has been
provided to Commission Staff auditors pursuant to an audit request.
THEREFORE, Idaho Power respectfully requests that the Commission, in
considering this Application, recognize that the sales price to Raft River wil be
approximately $44,000.00 rather than the $72,000.00 originally set out in the Application.
All other portions of the Application are unchanged and continue to be true and correct as
set out in the Application.
DATED this 21st day of December 2009.
(l)~-
BARTON L. KLINE
Attorney for Idaho Power Company
MOTION TO AMEND APPLICATION - 2
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 21st day of December 2009 I served a true and
correct copy of the within and foregoing MOTION TO AMEND APPLICATION upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Raft River Rural Electric Cooperative, Inc.
Jerry R. Rigby
RIGBY, ANDRUS & RIGBY, CHARTERED
P.O. Box 250
25 North Second East
Rexburg, Idaho 83440
Heber Carpenter
General Manager
Raft River Rural Electric Cooperative, Inc.
P.O. Box 617
Malta, Idaho 83342
MOTION TO AMEND APPLICATION - 3
-- Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email neil.price(ápuc.idaho.gov
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email hcarpent(âatcnet.net
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email jrigby(árex-law.com
~LC
Barton L. Kline