Motion.pdf

BARTON L. KLINE ISB #1526
Idaho Power Company
P. 0. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
Attorney for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-02-8
MOTION FOR THE COMMISSION TO
TAKE ADMINISTRATIVE NOTICE OF
THE GARNET REPORT
IN THE MATTER OF THE FILING BY
IDAHO POWER COMPANY OF ITS
2002 ELECTRIC INTEGRATED
RESOURCE PLAN (IRP).
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company"),
and hereby requests that the Commission take administrative notice in this proceeding
of the Report to the /PUC of Replacing the Garnet Power Purchase Agreement
("PPA ") filed with the Commission on October 30, 2002 (Garnet Report). This request
is based on the following:
1. Contemporaneous with the filing of this Motion, in accordance with
Order No. 29085, Idaho Power has filed the Garnet Report outlining the Company's
plans for replacing the Garnet PPA in the Company's resource stack.
2. As noted in the letter transmitting the Garnet Report to the
Commission, the Garnet Report contains trade secrets as that term is defined in Idaho
MOTION FOR ADMINISTRATIVE NOTICE, Page 1
Code§ 9-3400. As a result, portions of the Garnet Report are presented to the
Commission as confidential documents. The redacted version of the Garnet Report,
which does not contain the commercially-sensitive information, has been included with
the Company's Reply Comments in this case, and copies have been served on the
commenting parties in this case.
3. As noted in the Garnet Report, the Company is currently pursuing
several wholesale firm purchase contracts and exchange agreements. As those
contracts are concluded, they will be presented to the Commission for approval for
ratemaking purposes. In addition, upon execution of appropriate confidentiality
agreements, the Company is willing to provide periodic updates to the Commission Staff
on the status of the contract negotiations and the timing for the issuance of RFPs for
additional generating resources to supplement any wholesale purchase contracts and
exchange contracts.
4. Idaho Power hereby requests that the Commission take
administrative notice of the Garnet Report in making its ultimate determination as to
whether or not to acknowledge the Company's 2002 IRP. Idaho Power is hopeful that
the Commission can expeditiously make a determination as to whether or not to
acknowledge the 2002 I RP as supplemented by the Garnet Report.
Based on the foregoing, Idaho Power respectfully requests that the
Commission:
1. Take administrative notice of the Garnet Report in its consideration
of the Company's 2002 IRP filing; and
MOTION FOR ADMINISTRATIVE NOTICE, Page 2
2. Expeditiously acknowledge the Company's 2002 IRP and conclude
this docket.
Respectfully submitted this 30th day of October, 2002.
Isl
BARTON L. KLINE
Attorney for Idaho Power Company
MOTION FOR ADMINISTRATIVE NOTICE, Page 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 30th day of October, 2002, I served a true
and correct copy of the within and foregoing MOTION FOR THE COMMISSION TO
TAKE ADMINISTRATIVE NOTICE OF THE GARNET REPORT upon the following
named interested persons/commenters by the method indicated below, and addressed
to the following:
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
4 72 W. Washington Street
P.O. Box 83720
Boise, ID 83720-0074
John J. McMahon
Attorney at Law
3339 S. Bridgeport Lane
Boise, ID 83706
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
William M. Eddie
Land and Water Fund of the Rockies
P.O. Box 1612
Boise, ID 83701
Bill Chisholm
Idaho Rural Council
19073 E. Highway 30
Buhl, ID 83316
Jeffrey C. Brooks
1027 Cayman Drive
Meridian, ID 83642
Roald Doskeland, President
Windland, Inc.
10480 Garverdale Court, Suite 804A
Boise, ID 83704
CERTIFICATE OF SERVICE, Page 1
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Jonna L. Weber
Citizens for Responsible Land Use
1 01 05 Gabi ca Street
P.O. Box 192
Middleton, ID 83644
Rick S. Koebbe
WindWorks, Inc.
5356 N. Cattail Way
Boise, ID 83703
CERTIFICATE OF SERVICE, Page 2
Isl
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BARTON L. KLINE