20091228Response.pdf

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December 24, 2009
Z009 DEC 28 AM 8: 16
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Idaho Public Utilities Commission
. Att: Ms. Jean Jewell, Commission Secretar
PO Box 83720
Boise, ID 83720-0074
Re:Case No. IPC-E-09-27
Dear Ms. Jewell:
On December 23fd, 2009 I received an email containing Idaho Power's response to Case No. IPC-
E-09-27 dated December i ith, 2009. I would like to respond as follows:
1. We notified Lisa Nordstrom that the complaint was from an Idaho corporation not an individual
with a dba and we are concerned that someone individually would be held accountable which
should not be the case. The complaint should be from BrunoBuilt, Inc. not Robert Bruno dba
BrunoBuilt Homes. That entity essentially does not exist.
2. In their response to our complaint, Idaho Power alleges that we were in receipt of brochures or
pamphlets from Idaho Power Company which explain their current standards of constrction.
They have no evidence that we have received any such documentation. In addition, our excavator
had not received any notification either.
3. Their response to our complaint alleges that our conduit was not sufficiently vertical to the side of
the house. We would like to point out that our complaint is very simple: Our conduit was in fact
sufficiently vertical to the side of the house and that Idaho Power interprets "sufficiently vertical"
differently from time to time, depending on what crew members happen to be on the job that
particular day. In our view, their inconsistencies make it impossible for any builder or
subcontractor to know what the Power Company really wants. Additionally, our excavator
informed me that in a conversation with Idaho Power he is in an agreement with us that our
conduit was sufficiently vertical based upon past practices installng conduit for Idaho Power.
4. Idaho Powerc1aims that BrunoBuilt, Inc. asserts that the conduit was not installed according to
their standards as specified in the reduced cost option brochure that we allegedly received. We
cannot concede an error if we know not what the standards are.
5. Idaho Power alleges that it is our opinion that we are being singled out over other contractors in
their assessment of a return trip fee. It is our opinion that on this paricular occasion we were
singled out over a difference of opinion with regard to what Idaho Power's standards and
specifications are.
6. On page 4 of their response, in section 3, Idaho Power alleges that BrunoBuilt, Inc. knew the
conduit didn't comply with their standard. This is not the case. As a matter of fact, BrunoBuilt,
Inc. and Paradise Excavation, Inc. argued that it did in fact comply with their standards.
7. We supplied a photograph depicting a temporar power pole that was installed at the same job
location with a height not over 4 feet tall. The photo showed that Idaho Power Company had in
fact attached a meter to that temporary service pole. Idaho Power Company's standards require
that meters be no lower than 5 feet above grade. However, they installed themeterinyway.
BRUNOBUIL T, INC.
947 E. Winding Creek
Eagle, Idaho 83616
Office: 208.938.2357
Fax: [phone]
ww.brunobuilt.com
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BRUNOBUILT
HOMES
Another example ofIdaho Power's arbitrar and capricious manner in which they enforce their so
called standards.
8. On the same page, The Power Company alleges that a piece of conduit not installed perfectly
parallel or perfectly vertical to the house poses a safety or health hazard. That is like saying a
power pole or utility pole installed by Idaho Power poses a health or safety hazard to the general
public. We all know there are thousands of not perfectly vertical poles that never hurt a sole.
9. Idaho Power alleges on page 5 that we are the only company singled out for a back charge. That
is not the case. Our complaint is that Idaho Power does this to everyone in the industr, one day
they approve someone's conduit installation and another day they don't. One day they tell us
have to use a 36" sweep, the next day we can use couplings and shorter sections. Our complaint
is that they are inconsistent in the enforcement of their alleged standards and specifications not
only with our company but with many companies in our industr including our excavator and
including our electrcians.
10. Our company has not received any notifications of any standards and specifications from Idaho
Power Company that we can remember within the last five years.
II. Once again, if Idaho Power Company would be consistent in their requests, implementation,
notifications of, and enforcements of their standards and specifications we would never have
these problems. Idaho Power Company should not be allowed to arbitrarily assess return trip
charges on any given job.
12. We have been in the home building business in Idaho Power Company's service area for the past
25 years. While we appreciate the Power Company's service to our industry, we have been
subject to the wavering standards and specifications this entire time. This is certainly an ongoing
problem.
13. Idaho Power does not accurately and consistently enforce their standards and specifications which
causes confusion, inaccuracies, improperly installed services etc. on the job sites. This is not the
fault of the cOntractor or the builder. Responsibilty lies solely on the shoulders of Idaho Power
to consistently enforce their standards and specifications in the field and they simply do not do
that.
Thank you.
cc. Barton L. Kline, Lisa D. Nordstrom, Greg Said, Scott Sparks
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BRUNOBUIL T, INC.
947 E. Winding Creek
Eagle, Idaho 83616
Office: 208.938.2357
Fax: [phone]
ww.brunobuilt.com