20030519Reply to PacifiCorp.pdf

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Robert C. Huntley ISB#894
HUNTLEY PARK LLP
250 So. Fifth Street, Suite 660
O. Box 2188
Boise, Idaho 83701
Telephone: [phone]
Facsimile: 208-388-0234
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ORIGINAL
Attorneys for Plaintiff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
DEL RAY HOLM Case No. PAC-03-
Petitioner
vs.
PETITIONER'S REPLY TO
P ACIFICORP'S ANSWER AND
MOTION TO DISMISS
UTAH POWER & LIGHT
COMPANY IP ACIFICORP
Respondent.
COMES NOW Del Ray Holm by and through his attorney, Robert C. Huntley, and presents
his reply to PacifiCorp s Answer and Motion to Dismiss as follows:
PacifiCorp incorrectly characterizes the Petition as being primarily a "request for
itemization of costs - we do indeed need an itemization ofthe costs but such is meaningless without
PacifiCorp providing the " core 0 four request" which is for specifications as to the I ines and
transformers so that a competitive bid can be made and a determination can be made whether
PacifiCorp is overcharging.
Attached hereto as Appendix A is a bid by Arco Electric Inc. based on its assessment
of the proper specifications for the project. The bid comes in at $47 234 which is approximately
000 BELOW that ofPacifiCorp. The bid is actually approximately $8 000 BELOW that of
PacifiCorp because the Arco bid contains $3 000 for secondary conductor which is not included
Reply to PacifiCorp s Answer and Motion to Dismiss -
in the PacifiCorp bid.
Petitioner respectfully requests:
(a)The PacifiCorp provide the specifications requested; and
(b)Regulation 12 be amended as necessary to provide for customer installation
of conversions; and
(c)The Commission adopt such other relief as necessary to insure that
PacifiCorp s monopoly not be used in a manner to inflict unfair and unjust and unreasonable charges
and rates upon the Idaho consumer.
DATED this 16th day of May, 2003.
Reply to PacifiCorp s Answer and Motion to Dismiss - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16th day of May, 2003, a true and correct copy of the
foregoing document was served on the below listed individuals by the method indicated below:
Mary S. Hobson
STOEL RNES
101 South Capitol Blvd., Suite 1900
Boise, ill 83702
Fax: [phone]
Hand Delivered
- U.S. Mail
Overnight Mail
Facsimile
John M. Eriksson
STOEL RNES
One Utah Center
201 S. Main St. Suite 1100
Salt Lake City, UT 84111
Fax: [phone]
Hand Delivered
US. Mail
Overnight Mail
Facsimile
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Robert C. Huntley
Reply to PacifiCorp s Answer and Motion to Dismiss - 3
05/16/2003 15: 26 2085228840 PAGE 05
ARCO ELECTRIC INC
O. Box 50429
Idaho FaUs, Idaho 83405
208-522-2185 Fax [phone]
Mail arco~srv.net
This proposal is valid for 30 days
From !11!12003, unless noted
Otherwise.
TO: Del Ray Holm
2725 East 500 North
Roberts, Idaho 83444
PROJECT: Underground Power conversion on two systems. A 450 HP
vertieallift pump, with a 150 HP booster pump. The other for a 350 lIP
verticalUft pump.
We propose to furaish aU labor, materials, equipment and app6eable taxes neeessary to
~omplete the electrieal installation on the above projec:t, as shown on the drawings and
described in the specifications.
Two Transformer Pads S8S3.
Meter bases, conduits, fittings 55,302.
Secondary Wire 5867.
Place wire in trench 52,383.
Road crossing, conduit and plaee wire in conduit 51,839.
18,000 feet of #1 260 mill 25KV TRXLP cable 518,720.
2 - each SOO KV A Transformers 14,400 Volts
277/480 Volts
$10,400.
Equipment 51,685.
Taxes, permits, overhead aDd profit 55,185.
Appendix---'L-
05/16/2003 15: 26 2085228840 PAGE 06
TOTAL 547,234.
This BID DOES NOT INCLUDE:
BoDd Premium (if required, add $566.81)
Cost of Utilities for conltmet1on purposes
ARCO ELECTRIC INC.
~$-
,/J
Anthony E. PusiDo
Vice President
State Liceue #C3513
Public Works ##11698-AAA-4 (14)
05/16/2003 15: 26 2085228840 PAGE 07
O. BOX!0419. m WEST ZST8 SlREET,
IDAHO FALLS, IDAHO 83405
TELEPHONE 1-~2115
FAX [phone]
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May 15, 2003
Mr. Del Ray Holm
2725 East 500 North
Roberts, Idaho 83444
Subject: Underground Power
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..-. L1ght. As WIth thel! proposal we have figured that you as the owner WIll
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:':~'~lIitrenching and backfill. We will provide the wire the road crossing, the
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;~r pad and transformer along with connections to ~our existing pumps.
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~(:~:~~~;f\~ According to our calculations #4 Alum 15kv cable is adequate for the loads
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'in question. Also we are proposing cross-link Polyethylene tmderground
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UP&L's proposal shows two 500 K.V A transformers and pad design.. This is
ok for the larger installation, however a 300 KV A transformer is adequate for
the smaller pump installation.
We are assuming you will be metering your pump installations at 480 Volt
I have assumed that some one else will remove the existing overhead line once your
undergroW1d work is installed. We look forward to this opportunity to work with you
on this project.
Sin erel
IF.
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Antho y E. Passino
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