20070914Motion to Vacate Comment Deadllines.pdf

HECC.
William M. Eddie (ISB #5800)
ADVOCATES FOR THE WEST
610 SW Alder St., Suite 910
Portland, OR 97205
Ph: [phone]
Fax: [phone]
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO INCREASE THE
PUBLISHED RATE ELIGIBILITY CAP FOR
WIND POWERED SMALL POWER
PRODUCTION FACILITIES; AND
TO ELIMINATE THE 90%/110%
PERFORMANCE BAND FOR WIND POWERED)
SMALL POWER PRODUCTION FACILITIES
CASE NO.IPC-07-
(Reference related cases
PAC-07-07 and AVU-
07-02)
MOTION TO VACATE COMMENT DEADLINES
Intervenors Renewable Northwest Project and NW Energy Coalition (together
RNP") hereby move the Commission to vacate the deadlines for submission of initial
and reply comments in the above-captioned matter and related cases PAC-07-07 and
A VU-07-02. RNP has conferred with counsel for Idaho Power Company, PacifiCorp,
and A vista, and represents to the Commission that the utilities do not oppose vacation of
the comment deadlines. If necessary, RNP will confer with the parties and provide a
status report to the Commission no later than October 1 2007, including proposed new
deadlines for initial and reply comments.
RNP requests this extension for two reasons. First, good faith settlement
negotiations have continued among the parties. RNP has reached a settlement agreement
in principle with two of the three utilities, and believes that an agreement in principle can
MOTION TO VACATE COMMENT DEADLINES --
be achieved with the third utility. However, there are a large number of parties in these
cases. RNP and the utilities have discussed the proposed settlement with several other
parties; however it will take several days at minimum to complete these discussions
among all parties. The requested vacation of the comment deadlines will allow
completion of these settlement discussions and preparation of settlement documents.
Second, in the event settlement is not achieved, RNP wishes to conduct additional
written discovery in these cases. RNP's requests for production will be significant in
scope, and will likely require the full 28-day time for response, as provided by Rule of
Procedure 225.03. The requested vacation of comment deadlines will allow the
development of a more complete record in this matter.
For the foregoing reasons, RNP requests the Commission vacate the deadlines for
initial and reply comments in the above-referenced matters. Ifnecessary, RNP will
provide a status report (including proposed new comment deadlines) for the
Commission s consideration no later than October 1 2007.
Dated this 13th day of September, 2007.
Respectfully submitted
William M. Eddie
On behalf of RNP and NW Energy Coalition
MOTION TO V ACA TE COMMENT DEADLINES -- 2
CERTIFICATE OF SERVICE
I hereby certify that on this 13TH day of September 2007, true and correct copies
of the foregoing MOTION TO VACATE COMMENT DEADLINES were delivered to
the following persons via overnight delivery (for the Commission) and U.S. Mail for all
other recipients. Electronic copies also were provided on this date to all parties of record.
Jean Jewell (Original and 7 copies)
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Robert M. Ellis, Esq.
4 Nickerson, Suite 301
Seattle, W A 98109
Barton Kline
Monica Moen
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Glenn Ikemoto
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, CA 94611
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Dean 1. Miller, Esq.
McDevitt & Miller, LLP
PO Box 2564
Boise, ID 83701
Don Reading
6070 Hill Road
Boise, ID 83703
Ronald K. Arrington
Associate Chief Counsel
John Deere Renewables, LLC
6400 NW 86th Street
PO Box 6600
Johnston, IA 50131
R. Blair Strong
Paine Hamblen, LLP
717 W. Sprague, Suite 1200
Spokane, W A 99220
Peter Richardson
Richardson & O'Leary
515 N. 2ih St.
Boise, ID 83702
Dean Brockbank
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
Brian Dickman
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
Michael G. Andrea
Staff Attorney
A vista Corporation
PO Box 3727
Spokane, W A 99220-3727
Ken Miller
Snake River Alliance
PO Box 1731
Boise, ID 83701
Rich Rayhill
Ridgeline Energy, LLC
720 W. Idaho Street, Suite 39
Boise, ID 83702
Gerald Fleischman
11535 W. Hazeldale Ct.
Boise, ID 83713
MOTION TO VACATE COMMENT DEADLINES -- 3
Brian D. Jackson
Renaissance Engineering & Design
2792 Desert Wind Rd.
Oasis, ID 83647-5020
M. J. Humphries
Blue Ribbon Energy, LLC
2630 Central Ave.
Idaho Falls, ID 83406
Gary Seifert
Kurt Myers
INL Biofuels & Renewable Energy
Technologies
PO Box 1625 , MS 3810
Idaho Falls, ID 83415-3810
William M. Eddie
MOTION TO V ACA TE COMMENT DEADLINES -- 4