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Mary S. Hobson (ISB # 2142)
STOEL RIVES LLP
101 S. Capitol Blvd., Suite 1900
Boise, Idaho 83702-5958
Telephone: (208) 389-9000
Facsimile: (208) 389-9040
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John M. Eriksson (Utah Bar #4827)
STOEL RIVES LLP
201 South Main Street, #1100
Salt Lake City, Utah 84111-4904
Telephone: (801) 328-3131
Facsimile: (801) 578-6999
Attorneys for PacifiCorp
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application ofPacifiCorp
for Approval of Idaho Compact Fluorescent
Light Bulb Program and for Approval of
Deferred Accounting Treatment
Case No. PAC-02-
P ACIFICORP'S REPLY TO STAFF'
COMMENTS
PacifiCorp submits the following comments in reply to the November 27, 2002
Comments of the Commission Staff ("Staff'
PacifiCorp disagrees with Staffs recommendation that amortization of the
deferred costs begin when distribution of the light bulbs is completed. PacifiCorp suggests that
the amortization period instead begin when the costs are included in rates, or January 1 2004
whichever occurs earlier. Such treatment would be consistent with the Staffs recommendation
and the Commission s approval of deferred accounting treatment of excess power costs in Order
No. 28630 (Case No. P AC-00-5). In that Order, the Commission ordered that the amortization
of deferred excess power costs begin January 1 , 2003 if a recovery mechanism was not approved
PACIFICORP'S REPLY TO STAFF'S COMMENTS - Page 1
sooner. The January 1 , 2003 date was slightly more than one year after the end of the deferral
period for the excess power costs.
PacifiCorp believes that similar treatment in this case, extending the beginning of
the amortization period to January 1 , 2004, is appropriate. Such treatment would be consistent
with Staffs belief that "DSM programs such as these can be a cost effective way to meet
customer demand and should not be discouraged by eliminating the opportunity for cost
recovery," (Staff Comments, p. 2), since beginning amortization immediately will reduce the
opportunity for cost recovery.
Respectfully submitted, this 2nd day of December, 2002.
STOEL RIVES LLP
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John M. Eriksson
Attorneys for PacifiCorp
PACIFICORP'S REPLY TO STAFF'S COMMENTS - Page 2
CERTIFICATE OF SERVICE
I hereby certify that on this 2nd day of December, 2002 , I served ACIFICORP'
REPLY TO STAFF'S COMMENTS as follows:
Ms. Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
iiewel1~puc.state.id.
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Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
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Brandi L. Gearhart, PLS
Legal Secretary to Mary S. Hobson
Stoel Rives LLP
P ACIFICORP'S REPLY TO STAFF'S COMMENTS - Page 3