20130618Replacement Page.pdf

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An IDACORP Company
tC;: Jllil lB Fii l: 12
LISA D. NORDSTROM
Lead Counsel
[e-mail]
June 18,2013
::.:
i I i t! I r
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-09
Glanbia Foods, !nc.'s Petition - Replacement Page 13 to ldaho Power
Company's Reply Comments
Dear Ms. Jewell:
It has come to ldaho PowerCompany's ("ldaho Powe/') attention that page 13 of its
Reply Comments contained page numbers in its footnotes that cited to pre-filed testimony
rather than the transcript. To conect this oversight, ldaho Power requests that the origina!
page 13 of its Reply Comments be replaced with the enclosed page 13. To that end,
enclosed are an original and seven (7) copies of replacement page 13.
lf you have any questions regarding this error or the enclosed replacement page,
please do not hesitate to contact the undersigned.
Sincerely,
-<-"0 f(^,ul-^,.*
Lisa D. Nordstrom
LDN:csb
Enclosures
cc: Service List
1221 W. ldaho st. (83702)
P.O. Box 70
Boise, lD 83707
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 18th day of June 20131 served a true and correct
copy of IDAHO POWER COMPANY'S LETTER TO JEAN D. JEWELL DATED JUNE 18,
2013, AND REPLACEMENT PAGE 13 TO IDAHO POWER COMPANY'S REPLY
COMMENTS upon the following named parties by the method indicated below, and
addressed to the following:
Gommission Staff
Weldon Stutzman
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
Glanbia Foods, Inc.
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
X Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
q reg @ richard sonandolearv. com
substation."2a Mr. Sterling testified that ldaho Power had not violated any of its rules or
its tariff when it required the proposed Schedule 19 customer to fund a portion of the
substation and, in fact, Mr. Sterling noted:
Customers could request service and possibly trigger
construction of new facilities to serve the ultimate maximum
load expected, and face no consequences if only a part of
the load (and revenue that goes along with it) materialized
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Power.2s
ln his testimony, Mr. Sterling also stated that the treatment of Schedule 19
customers was "inconsistent and discriminatory,"26 because "it is discriminatory
whenever one customer has to pay for substation facilities and another customer, who
may require the same or even larger substation capacity, does not have to pay just
because extra substation capacity is atready availabte."27 On Rebuttal, Company
witness Mr. Said responded to Mr. Sterling's statement by pointing out that:
A new customer who requires no additiona! facilities
provides a benefit to other ldaho Power customers in that no
additional costs are added to the system, but the existing
costs can be spread across a greater load, thereby
effectively reducing the cost responsibility of other customers
Conversely, a new customer who requires additional
facilities, but is not required to make a CIAC, adds total costs
to be recovered by the Company. Those additional costs
adversely impact existing customers^, since those customers
must absorb those additional costs.28
'o Case No. IPC-E-00-12, Sterling Direct Testimony, Tr. at 131.
2s Case No. IPC-E-00-12, Sterling Direct Testimony, Tr. at137.
'u Case No. IPC-E-00-12, Sterling Direct Testimony, Tr. a|143.
27 ld.
" Case No. IPC-E-00-12, Said Rebuttal Testimony, Tr. a|277.
IDAHO POWER COMPANY'S REPLY COMMENTS - 13