20051107Answer.pdf

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BARTON l. KLINE
Senior Attorney
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November 4, 2005
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
Re:Case No. I PC-05-
Idaho Power Company s Answer
Dear Ms. Jewell:
Please find enclosed for filing an original and seven (7) copies of the
Company s Answer in the above-entitled case.
I would appreciate it if you would return a stamped copy of this transmittal
letter for our files in the enclosed self-addressed stamped envelope.
Barton L. Kline
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Enclosures
Telephone [phone] Fax [phone], E-mail BKline(ij)idahopower.com
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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: [phone]
E-mail: BKline
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idahopower.com
MMoen
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idahopower.com
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Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
CASSIA WIND TO DETERMINE
EXEMPTION STATUS.ANSWER
CASE NO. IPC-05-
Idaho Power Company ("Idaho Power" or "Company ), in accordance with
RP 057, hereby answers the Petition of Cassia Gulch Wind Park LLC and Cassia Gulch
Wind Farm LLC ("Cassia Wind") in the above-entitled case as follows:
Idaho Power admits that the Commission issued Order No. 29839 in
Case No. IPC-05-22. Order No. 29839 speaks for itself. The balance of the statements
in Paragraph No.1 constitute legal conclusions and arguments , not allegations of fact that
can be admitted or denied. As such, Idaho Power denies the same.
Idaho Power admits that the Commission issued Order No. 29872 in
Case No. IPC-05-22. Order No. 29872 speaks for itself. The balance of the statements
in Paragraph 2 constitute legal conclusions and arguments , not allegations of fact that can
be admitted or denied. As such , Idaho Power denies the same.
ANSWER, Page
The Affidavit of Jared Grover, which was filed with the Petition but
was not included by reference in the Petition, contains a mixture of factual assertions, Mr.
Grover s opinions and legal conclusions. Some of the information described in the
Affidavit has been provided to Idaho Power and some of it has not been. For these
reasons, Idaho Power is without sufficient information to verify the truth or falsity of the
factual allegations contained in the Affidavit of Jared Grover and, therefore, denies the
same.
Service of Pleadinqs - Communications with reference to this case
should be sent to the following:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, ID 83707
bkline (g? idahopower.com
mmoen (g? idahopower.com
John R. Gale
Vice President - Regulatory Affairs
Idaho Power Company
O. Box 70
Boise , ID 83707
rqale
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idahopower.com
Requested Relief - Cassia Wind has not stated a claim for relief
which can be granted and the Petition should be denied by the Commission.
DATED at Boise, Idaho , this 4th day of November, 2005.
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BAR ON L. Kl
MONICA B. MOEN
Attorneys for Idaho Power Company
ANSWER, Page 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 4th day of November, 2005, I served a
true and correct copy of the within and foregoing ANSWER upon the following named
parties by the method indicated below, and addressed to the following:
Dean J. Miller
McDevitt & Miller LLP
420 W. Bannock Street
Boise, Idaho 83702
Hand Delivered
x U.S. Mail
Overnight Mail
FAX
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CERTIFICATE OF SERVICE