20041217Reply Comments.pdf

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MONICA MOEN ISB #5734
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707
Telephone No. [phone]
FAX Telephone No. [phone]
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Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
IMPLEMENT AN IRRIGATION PEAK
CLIPPING PROGRAM
REPLY OF IDAHO POWER
COMPANY TO THE COMMENTS
OF THE COMMISSION STAFF AND
THE IDAHO IRRIGATION PUMPERS
ASSOCIATION
CASE NO. IPC-04-
Idaho Power Company ("Idaho Power" or "the Company ) hereby submits
the following reply concerning the comments offered in this matter by the Staff of the
Idaho Public Utilities Commission ("Commission Staff") and by the Idaho Irrigation
Pumpers Association ("the Pumpers ) on December 14 , 2004.
The Company appreciates the general support of the proposed Irrigation
Peak Clipping Program ("Peak Clipping" or "Program ) by both the Commission Staff
and the Pumpers and agrees that the Program should be approved without delay for
system-wide implementation.
REPLY COMMENTS OF IDAHO POWER COMPANY -
The Pumpers generally favor the Program but identify issues concerning
the Program s interruptibility schedule, demand credit derivation and customer eligibility
provisions for which they would like more information. The Commission Staff also
recommends approval of the Program but encourages the Company to explore certain
Program options. The Company met with the Commission Staff and representatives of
the Pumpers on December 14 , 2004 to discuss these Program issues and to provide
additional information on the rationale for the Program design. The Company continues
to be willing to meet with the Pumpers and Commission Staff at any time to address
these or other issues related to the Program. Nothing in either the Commission Staff's
or the Pumpers' comments suggest that Commission consideration of this matter should
be delayed by further discussion of the issues raised by either of these two parties.
The Company agrees with the recommendation of the Commission Staff
that the Company file a report on the results of the system-wide program by
December 1 , 2005. The Company also agrees with the recommendation made by both
parties that the Company continue to evaluate the potential for more program flexibility
and further increases in the demand credit.
Respectfully submitted this 17th day of December 2004.
MONICA B. MOEN
Attorney for Idaho Power Company
REPLY COMMENTS OF IDAHO POWER COMPANY - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of December 2004, I served
true and correct copies of the above and foregoing REPLY COMMENTS OF IDAHO
POWER COMPANY to the following parties:
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, ID 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
Randall C. Budge
Racine , Olson , Nye , Budge & Bailey,
Chartered
201 E. Center
O. Box 1391
Pocatello IO 83204-1391
Hand Delivered
S. Mail
Overnight Mail
FAX
/J.
MONICA B. MOEN
CERTIFICATE OF SERVICE