20110728Motion to extend comment deadline.pdf

KRSTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
TELEPHONE: [phone]
E-MAIL: kris.sasser(ápuc.idaho.gov
BARNO. 6618
RECEIVED
20t I JUL 28 Pr1 2= 52
STRET MAILING ADDRESS:
472 WEST WASHINGTON STREET
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR A )
DETERMINATION REGARDING THE FIRM )
ENERGY SALES AGREEMENT WITH )
INTERCONNECT SOLAR DEVELOPMENT, )
LLC, FOR THE SALE AND PURCHASE OF )ELECTRIC ENERGY. )
CASE NO. IPC-E-ll-IO
COMMISSION STAFF MOTION
TO EXTEND DEADLINE FOR
FILING COMMENTS
On June 17, 2011, Idao Power Company filed an Application with the Commission
requesting acceptance or rejection of a 25-year Firm Energy Sales Agreement (Agreement)
between Idaho Power and Interconnect Solar Development LLC (Interconnect Solar). On July 8,
2011, the Commission issued a Notice of Application and Notice of Modified Procedure setting
a comment deadline of August 4, 2011. Idaho Power and Interconnect Solar were given until
August 11,2011, to fie reply comments.
The Interconnect Solar Agreement is the first solar project to have rates calculated
based on the IRP Methodology. Application of the IRP Methodology to a solar project raises
new, unique issues, i.e., the introduction of heavy load peak pricing, separate calculation of
energy and capacity rate components, and application of price adjustment mechanisms not
typically used with the IRP Methodology. Staffs first set of production requests has triggered
additional questions and the need for additional review. Staff expects to fie at least one more
COMMISSION STAFF MOTION
TO EXTEND DEADLINE FOR COMMENTS 1
round of production requests. We anticipate that Idaho Power may require a full 21 days to
compile its responses.
Based on the complexity of the issues presented in this case, and in order to provide
Staff enough time to adequately review the Agreement, we request an extension for filing
comments. We, therefore, propose the following modifications:
Staff comments due
IdahoPower/Interconnect Solar reply
September 29,2011
October 6, 2011
Staff respectfully requests that the Commission issue an Order approving the
modified schedule.
Respectfully submitted this ;)*' day of July 2011.
~~(L~_Kriine A:asser
Deputy Attorney General
N:IPC-E-I l-lO_Motion to Extend Comments_ks
COMMISSION STAFF MOTION
TO EXTEND DEADLINE FOR COMMENTS 2