20040521Motion to Withdraw Application.pdf

BARTON L. KLINE , ISB # 1526
Idaho Power Company
1221 West Idaho Street
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
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Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL)
OF AN AGREEMENT FOR SALE AND
PURCHASE OF ELECTRIC ENERGY
BETWEEN IDAHO POWER COMPANY AND
THE J.R. SIMPLOT COMPANY
CASE NO. I PC-04- 7
MOTION TO WITHDRAW
APPLICATION
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company
by and through its attorney, and on behalf of itself and the J.R. Simplot Company
Simp lot"), hereby moves to withdraw the pending Application for approval of the
February 19 , 2004 Firm Energy Sales Agreement between Idaho Power and Simplot ("the
Agreement"
) .
Idaho Power and Simplot have agreed to cancel the February 19 , 2004
Agreement and to enter into a new Firm Energy Sales Agreement which should
eliminate the major concerns expressed in the Commission Staff's comments in this
case.
Upon execution of the new Firm Energy Sales Agreement, the Company
will file the new Firm Energy Sales Agreement for approval by the Commission.
MOTION TO WITHDRAW APPLICATION , Page
NOW , THEREFORE, Idaho Power respectfully requests that the
Commission grant this Motion and conclude this proceeding.
DATED at Boise , Idaho, this 20th day of May, 2004.
BAR ON L. KLINE
Attorney for Idaho Power Company
MOTION TO WITHDRAW APPLICATION , Page 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 20th day of May, 2004, I served a true
and correct copy of the within and foregoing MOTION TO WITHDRAW APPLICATION
upon the following named parties by the method indicated below, and addressed to the
following:
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
Peter J. Richardson
Richardson & O'Leary PLLC
99 E. State Street, Suite 200
O. Box 1849
Eagle, Idaho 83616
Hand Delivered
S. Mail
Overnight Mail
FAX
David Hawk
R. Simplot Company
O. Box 27
Boise , Idaho 83707
Hand Delivered
S. Mail
Overnight Mail
FAX
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BARTON L. KLINE
CERTIFICATE OF SERVICE