The URL can be used to link to this page

Home My WebLink About20030930Motion for Ratification.pdfJames F. Fell, ISB 2274 George M. Galloway STOEL RIVES LLP 900 SW Fifth Avenue, Suite 2600 Portland, OR 97204 Telephone: (503) 224-3380 Fax Number: (503) 220-2480 RECEiVED illFiLED 2~a3 SEP 30 MilO: IDt",HO FUBLiC UTIUT'tES COt1MISSION Attorneys for PacifiCorp d/b/a Utah Power & Light Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case No. PAC-02- In the Matter of the Investigation of Interjurisdictional Issues Affecting PacifiCorp d/b/a Utah Power & Light Company Motion ofPacifiCorp for Ratification of Inter- Jurisdictional Cost Allocation Protocol Since April 2002, PacifiCorp (or the "Company ) and other interested parties have engaged in a collaborative Multistate Process ("MSP") investigating various issues faced by the Company as a multi-state utility subject to the jurisdiction of six state regulatory commissions. The MSP was endorsed by the Commission when it opened this investigatory docket. MSP meetings were attended in person by in excess of 50 individuals representing some 18 entities from the states of Utah, Oregon, Wyoming, Washington and Idaho. These included representatives of state commission policy staffs, advocacy staffs, industrial customers and consumer groups. A number of other people participated by telephone. In addition to the MSP meetings, the Company participated in a number of separate meetings with representatives from individual states or groups of states and conducted various technical workshops. More formal hearings were conducted in some states to review MSP progress. There were weekly telephone conferences and e-mail exchanges. There was a dedicated web site for information sharing. Throughout the process, the Company responded to a large number of formal and informal data requests from the parties. Motion ofPacifiCorp for Commission Ratification of Interjurisdictional Cost Allocation Protocol - The last MSP meeting occurred in July 2003. At that meeting, the Company was encouraged to develop and file a specific proposal for resolving MSP issues that was consistent with the results of the analyses that had been conducted and responsive to the views expressed by MSP participants. PacifiCorp has developed an "MSP Solution" which is embodied in a document entitled PacifiCorp Inter-Jurisdictional Cost Allocation Protocol" (the "Protocol") which is attached to and incorporated in this motion. The Protocol describes how PacifiCorp s generation transmission and distribution costs will be allocated or assigned to PacifiCorp s six retail jurisdictions. The Protocol also describes mechanisms for ensuring continued dialog among interested parties regarding PacifiCorp inter-jurisdictional cost allocation issues and procedures for resolving concerns and inconsistent policies that may arise among the Company s state jurisdictions in the future. PacifiCorp moves that the Commission ratify the Protocol. PacifiCorp s motion is supported by the attached pre filed direct testimony and exhibits of Andrew N. MacRitchie, Andrea L. Kelly, Gregory N. Duvall and David L. Taylor. As more fully explained in the prefiled testimony, Commission ratification of the Protocol will resolve current differences among PacifiCorp' s retail jurisdictions concerning needed new resources and cost allocation methods. Ratification will afford PacifiCorp assurance that it will have a reasonable opportunity to recover prudent investments in new generation and transmission facilities and required improvements to existing facilities. This, in turn, will ensure that the Company s customers continue to receive safe and reliable electricity service at reasonable pnces. Motion ofPacifiCorp for Commission Ratification of Interjurisdictional Cost Allocation Protocol - 2 DATED: September 29 2003. Respectfully submitted STOEL RIVES LLP Attorneys for PacifiCorp, d/b/a Utah Power & Light Company Motion ofPacifiCorp for Commission Ratification of Interjurisdictional Cost Allocation Protocol - 3 CERTIFICATE OF SERVICE I certify that I have served the foregoing Motion on the persons shown below by mailing a copy by First Class U.S. Mail , postage prepaid , properly addressed to each. Randall Budge O. Box 1391 201 East Center Pocatello, ID 83204-1391 Terri Carlock 472 W Washington Boise, ID 83702 Madonna Faunce 472 W Washington Boise, ID 83702 Jean D. Jewell Idaho Public Utilities Commission 472 W Washington Boise , ID 83702-5983 Joe Leckie 472 W Washington Boise, ID 83702 David Schunke 472 W Washington Boise , ID 83702 Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 W Washington Boise, ID 83702 James R. Smith Monsanto company O. Box 816 Highway 34 North Soda Springs, ID 83276 Peter Richardson Richardson & O'Leary O. Box 1849 99 East State Street Eagle , ID 83616 Clyde Dailey AARP 3080 E Gentry Way, Ste.100 Meridian , ID 83642 Dated this 29th day of September, 2003.