20050401Motion to withdraw application.pdf

BARTON L. KLINE , ISB # 1526
MONICA B. MOEN , ISB # 5734
Idaho Power Company
1221 West Idaho Street
O. Box 70
Boise , Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
Attorneys for Idaho Power Company
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BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO NSTITUTE A
PERFORMANCE-BASED PilOT
DEMAND-SIDE MANAGEMENT
INCENTIVE PROGRAM.
MOTION TO WITHDRAW
APPLICATION
CASE NO. IPC-05-
COMES NOW , Idaho Power Company ("Idaho Power" or the "Company
and in accordance with RP 056, hereby moves the Commission for an order authorizing
Idaho Power to withdraw the Application the Company filed in this case on February 18
2005. In support of this Motion, the Company submits the following:
On February 18, 2005 , Idaho Power filed an Application seeking
authority to institute a pilot program intended to remove disincentives that hinder the
Company s pursuit of cost-effective demand-side management ("DSM") resources.
the Application , the Company described two DSM programs proposed for inclusion in
the pilot program. These two DSM programs were the Energy Star(8) Homes Northwest
Program and the Rebate Advantage For New Manufactured Homes Program. The
Energy Star(8) Homes Northwest Program involves new residential dwelling construction
MOTION TO WITHDRAW APPLICATION , Page
and the Rebate Advantage Program applies to the purchase of new manufactured
homes.
Immediately following the filing of the Application, several parties
that had participated in the collaborative process to develop the pilot program began
discussing the possibility that there may be other DSM programs that would be better
candidates for testing the mechanism to remove disincentives that were the basis for
the pilot program. Based on those discussions , all of the parties to the collaborative
process have now concluded that it would be desirable to identify other more suitable
DSM programs to use in the pilot program. The parties have agreed to continue to
pursue the development of an incentive-based pilot program that would be substantially
similar to the pilot program described in the Application but to use other Idaho Power
DSM programs in the pilot program.
The Company has concluded that procedurally it would be
preferable to withdraw this Application in its entirety and make a new Application when
a suitable DSM program or programs are identified rather than attempting to amend this
Application to apply to yet-to-be-determined DSM programs.
The Company wishes to emphasize that it will continue to pursue
both of the above-mentioned DSM programs even though the Company is requesting
that this Application be withdrawn.
WHEREFORE, Idaho Power respectfully requests that the Commission
issue its order granting this Motion and authorizing Idaho Power withdraw its Application
to implement the pilot program described in the Application.
MOTION TO WITHDRAW APPLICATION , Page 2
DATED at Boise , Idaho, this 31st day of March, 2005.
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BARTON L. KLINE
Attorney for Idaho Power Company
MOTION TO WITHDRAW APPLICATION, Page 3