20101001Motion to Permit Reply Comments etc.pdf

McDevitt & Miller LLP
Lawyers
[phone]
[phone] (Fax)
CE420 W. Bannock Street
P~~iS~~;d~~~4~~~irnoCl - \ AM to: 30 Chas. F. McDevitt
Dean J. (Joe) Miler
October 1,
Via Hand Delivery
Jean Jewell, Secretar
Idaho Public Utities Commssion
472 W. Washigton St.
Boise, Idao 83720 ~;;
RE: Yellowstone Power Inc.; Case No. IPC-E-l0~
Dear Ms. Jewell:
Enclosed for fig, please fid an orial and seven r1) copies of Yellowstone Power Inc.'s Motion
to Permt Filg of Reply Comments and Establish a Reply Comment Filg Date.
Kidly retu fie staped copies to me.
Very try yours,
McDEVT & MIll IL~U1
Dean J. Mier
DJM/hh
Enclosures
-Jc:z-(!-0:o
Dean J. Miler (ISB No. 1968)
Chas F. McDevitt (ISB No. 835)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. BOX 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
joeCâmcdevitt-miler.com
RECE
in\U Gei - \ I\M \0: 30
Attorney for Yellowstone Power Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICA nON
OF IDAHO POWER COMPANY FOR
APPROVAL OF A FIR ENERGY SALES
AGREEMENT WITH YELLOWSTONE
POWER, INC., FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY.
CASE NO. IPC-E-lO-W:;;:
MOTION TO PERMIT FILING OF
REPLY COMMENTS AND
ESTABLISH A REPLY COMMENT
FILING DATE
COMES NOW Yellowstone Power Inc., (Yellowstone) and moves the
Commission for an Order to Permit the Filng of Reply Comments and Establish a Reply
Comment filing date, and in support thereof, respectfuly shows as follows:
1. The Application in this case seeks approval of a Firm Energy Sales Agreement
(Agreement) between Yellowstone and Idao Power Company contaning
published avoided cost rates in existence prior to March 16,2010. The
Commission's Notice of Application, issued herein, established an initial
Comment deadline of October 1, 2010, but did not establish a deadline for the
fiing of Reply Comments.
2. Commission Staffhas fied Comments of the Commission Staff dated October 1,
2010, in which Staf concludes, "Staf is unable to recommend that the
MOTION TO PERMIT FILING OF REPLY COMMENTS AND ESTABLISH A REPLY
COMMENT FILING DATE-l
Commission approve the Idaho Power/Yellowstone Agreement.. ." (Staff
Comments Pg. 8).
3 . Yellowstone disagrees with the Staff conclusion and desires to present arguent
and evidence demonstrating that the Agreement should be approved as submitted.
4. Yellowstone recommends that the Commission establish a Reply Comment filing
date of October 18, 2010.
Respectfully Submitted ~ day of October, 2010.
McDEVITT & MILLER LLP
BY:~ll
e J.Miler (ISB No. 1968)
Attorneys for Yellowstone Power Inc.
MOTION TO PERMIT FILING OF REPLY COMMENTS AND ESTABLISH A REPLY
COMMENT FILING DATE-2
CERTIFICATE OF SERVICE
I hereby certify that on the Jf day of October, 2010, I caused to be served, via
the methodes) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secreta
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
j jewel(ipuc.state.id. us
Krstine Sasser
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
kristine. sasseriIpuc. idaho. gov
Donovan E. Walker, Esq.
Idaho Power Company
1221 W. Idaho Street
P.O. Box 70
Boise, ID 83707
dwalker(iidahopower.com
Hand Delivered ~
U.S. Mail ....
Fax ....
Fed. Express ....
Email ....
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
....
....
....
....(
....
....
....
....
iÄ
By:_i1:t i 1bi\R,
McDEVITT & MILLER LLP
MOTION TO PERMIT FILING OF REPLY COMMENTS AND ESTABLISH A REPLY
COMMENT FILING DATE-3