20110825Motion to modify deadline.pdf

RECEIVED
KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
TELEPHONE: [phone]
E-MAIL: kris.sasser(ipuc.idaho.gov
BARNO. 6618
2UI! AUG 25 AM 9: 31
STREET 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 MODIFY DEADLINE FOR
FILING COMMENTS
On June 17, 2011, Idaho Power Company fied an Application with the Commission
requesting acceptace or rejection of a 25-year Firm Energy Sales Agreement (Agreement)
between Idaho Power and Interconnect Solar Development LLC (Interconnect Solar, the
Project). 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.
On July 28, 2011, Staff fied a Motion to Extend the original comment deadline.
Staff indicated that, as the first solar project to have rates calculated;.based on the IRP
Methodology, the Interconnect Solar Application raised new, unique issues that Staff needed
additional time to review. Based on the issues presented by Staff, on August 2, 2011, the
Commission issued an Order extending the comment deadline until September 29, 2011, and
reply comment deadline until October 6, 2011. Order No. 32308.
COMMISSION STAFF MOTION
TO MODIFY DEADLINE FOR COMMENTS 1
On August 3, 2011, Interconnect Solar fied an Answer to Staffs Motion. While
Interconnect Solar acknowledged receipt of Staffs Motion on Friday, July 29, 2011, the Project
maintained that it did not have an opportnity to respond prior to the Commission granting
Staffs Motion. Interconnect Solar explained that, while it did not oppose additional time for
Staff to complete its investigation, it did oppose the extended schedule requested by Staff.
Interconnect Solar argued that if Staffs schedule was adopted the project would no longer be
commercially viable and would be forced into default in its contractual obligation to Idaho
Power.
Following Interconnect Solar's Answer, Staff, the Project and Idaho Power have
worked together to expedite discovery. Staff now believes that it has received adequate
information to be prepared to fie comments in advance of the September 29, 2011, deadline.
We, therefore, propose the following modifications:
Staff comments due
IdahoPower/Interconnect Solar reply
September 9, 2011
September 16, 2011
Neither Interconnect Solar nor Idaho Power oppose Staffs Motion to Modify the comment
deadlines.
Staff respectfully requests that the Commission issue an Order approving the
modified schedule.
5THRespectfully submitted this:t - day of August 2011.
~D)a.~4A
Kristine A. Sasser
Deputy Attorney General
N:IPC-E-II-IO_ks
COMMISSION STAFF MOTION
TO MODIFY DEADLINE FOR COMMENTS 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF AUGUST 2011,
SERVED THE FOREGOING COMMISSION STAFF MOTION TO MODIFY
DEADLINE FOR FILING COMMENTS, IN CASE NO. IPC-E-II-I0, BY E-MAILING
AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOV AN E WALKER
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalker(iidahopower.com
RANDY C ALLPHIN
ENERGY CONTRACT ADMIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rallphin(iidahopower.com
RANDY HEMMER MGR
INTERCONNECT SOLAR
DEVELOPMENT LLC
3777 TWILIGHT DR
BOISE ID 83703
E-MAIL: randyhemmer(iclearwire.net
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 WHAYS ST
BOISE ID 83702
E-MAIL: ronCfwiliamsbradbury.com
E-MAIL ONLY:
PETER J RICHARDSON
GREG ADAMS
RICHARDSON & O'LEARY PLLC
pete(irichardsonandoleary. com
greg(irichardsonandoleary .com
~SECRETARY ~
CERTIFICATE OF SERVICE