20020320Timothy Shurtz Petition for Clarification.pdf

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Timothy Shurtz Pro Se
Councilman
411 S. Main
Firth, Idaho 83236
208-346-6523
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Intervenor
BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION
In the Matter of the Application of
PACIFICORP dba Utah Power & Light
Company for Approval of Changes to Its
Electric Service Schedules
CASE NO. PAC-02-
PETITION FOR
CLARIFICATION
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Intervernor, Timothy Shurtz, respectfully petitions and requests the
Honorable Commissioners to clarify, explain and enunciate the meaning of
the terminology and concepts used to justify and substantiate the
provisions of this Commissions Order No. 28213 in Case No. PAC-99-
wherein in this Commission s Findings of Fact and Conclusions of Law it
found as follows:
1. Page 8. u2. At a minimum , Scottish Power shall not seek a
general rate increase for its Idaho service territory effective prior to
January 1, 2002.
2. Page 14.PacificCorp/ScottishPower shall not subsidize its
non-regulated businesses with its regulated businesses.
3. Page 31. 'We Find:
While a general fear of rate increases was expressed, there was no
verifiable, quantifiable evidence presented that rates would go up due to
the merger.
Regardless, any doubt that might arguably have existed regarding
this issue was definitively put to rest by the filing of the Joint
Applicants' Notice of Merger Credit Comitment. As a final and irrefutable
measure to ensure that rates will not increase as a result of the merger
we hereby impose the additional condition (Merger Approval Condition No.
2) that following the merger, PacificCorp shall not seek a general rate
increase effective prior to January 1, 2002. This literally quarantees that
PacifiCorp s customers will see an immediate rate reduction lasting
2 years through the combination of the merger rate credit and the
moratorium on general rate increases imposed herein. This rate reduction
would not have occurred absent the merger.
Intervenor does further request the Commission to clarify how the
proposed retroative or udeferred excess net power costs" recovery sought
now are not in reality an attempt to avoid the umoratorium" agreed to
inducing this Commission to accept the merger then being considered.
other words, why is a collection now, and in the immediate future, of the
past two years deferred excess net power costs, not in reality a violation
of the Commissions Order of a umoratorium on general rate increases
imposed herein" quoted above?
Respectfully submitted this 18th day of March, 2002.
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7:;;~~-~tGJrtz, Intervenor
CERTIFICATE OF SERVICE
I hereby certify that on 'this _day of March, 2002, a true and
correct copy of the foregoing was served on the following via U. S. mail or
by hand delivery:
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
P. O. Box 83720
Boise, Idaho 83720-0074
Eric Olson, Esq.
P. O. Box 1391
201 E. Center
Pocatello, Idaho 83204-1391
Anthony J. Yankel
28814 Lake Road
Bay Village, OH 44140
Randall C. Budge, Esq.
P. O. Box 1391
201 E. Center
Pocatello, Idaho 83204-1391
James R. Smith
Senior Accounting Specialist
Monsanto Company
P. O. Box 816
Soda Springs, Idaho 83276
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