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Home My WebLink About20140214Motion to Motions.pdf7!lmloNPO1,ER= : f-.: ?frti; Ilii i,: iii li: IE DONOVAN E. WALKER Lead Counsel dwa! ker@idahopower.com February 14,2014 VIA HAND DELIVERY Jean D. Jewel!, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, ldaho 83702 Re: Case No. IPC-E-13-22 Update to Wind Integration Rates and Charges - ldaho Power Company's Motion Regarding Response to Motions/Joinders Dear Ms. Jewell: Enclosed forfiling in the above matterare an originaland seven (7) copies of ldaho Power Company's Motion Regarding Response to Motions/Joinders. An IDACORP Company Q*,2u/uDonovan E. Walker DEW:csb Enclosures 1221 W. ldaho St. (83702) P.O. Box 70 Boise, lD 83707 DONOVAN E. WALKER (lSB No. 5921) JULIA A. HILTON (lSB No. 7740) ldaho Power Company 1221West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalker@idahopower.com ih ilto n@ idahopower. com Attorneys for ldaho Power Company IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION TO UPDATE ITS WIND INTEGRATION MTES AND CHARGES. It )) CASE NO. !PC-E-13-22 )) TDAHO POWER COMPANY',S BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION MOTION REGARDING RESPONSE TO MOTIONS/JOINDERS ln accordance with RP 57 and RP 256, ldaho Power Company ("ldaho Powe/') hereby provides notice that its Answer to the Motions/Joinders filed by the intervening parties to this proceeding will be filed on February 21,2014, fourteen (14) days following the filing of the last Motion/Joinder pursuant to RP 256.04. ln the alternative, ldaho Power respectfully requests the ldaho Public Utilities Commission ("Commission") grant additional time with which to answer the Motions/Joinders to February 21,2014. I. BACKGROUND Idaho Power filed its Application to update its wind integration rates and charges on November 29, 2013. On December 31 , 2013, the Commission issued a Notice of Application and Notice of lntervention Deadline, with an intervention deadline of January IDAHO POWER COMPANY'S MOTION REGARDING RESPONSE TO MOTIONS/JOINDERS - 1 21, 2014. The following parties intervened in the case: ldaho Winds, LLC ("ldaho Winds"); Snake River Alliance ("SRA"); Cold Springs Windfarm, LLC ("Cold Springs"); Desert Meadow Windfarm, LLC ("Desert Meadow"); Hammett Hill Windfarm, LLC ("Hammett Hill"); Mainline Windfarm, LLC ("Mainline"); Ryegrass Windfarm, LLC ("Ryegrass"); Two Ponds Windfarm, LLC ("Two Ponds"); Cassia Windfarm LLC ("Cassia"); Hot Springs Windfarm, LLC ("Hot Springs"); Bennett Creek Windfarm, LLC ("Bennett Creek"); Cassia Gulch Wind Park, LLC ("Cassia Gulch"); Tuana Springs Energy, LLC ("Tuana"); High Mesa Energy, LLC ("High Mesa"); Renewable Northwest Project ("RNP"); American Wind Energy Association ("AWEA"); ldaho Wind Partners l, LLC ("ldaho Wind Partners"); Meadow Creek Project Company, LLC ("Meadow Creek"); and Rockland Wlnd Farm, LLC ("Rockland"). The Commission granted intervention for each of the above. On January 31 , 2014, Cold Springs, Desert Meadow, Hammett Hill, Mainline, Ryegrass, Two Ponds, Cassia, Hot Springs, Bennett Creek, Cassia Gulch, Tuana, and High Mesa collectively filed a Motion to Dismiss based upon Idaho R. Civ. Pro. 12(c) ("Cold Springs Motion to Dismiss"). On February 7,2014, AWEA and RNP filed Comments in support of the Cold Springs Motion to Dismiss. SRA also filed Comments on the Cold Springs Motion to Dismiss. Meadow Creek, Rockland, and ldaho Wind Partners filed to join in the Cold Springs Motion to Dismiss with additional comments. On February 7, 2014, ldaho Winds also filed a Motion to Dismiss. II. ANSWERS TO MOTIONS/JOINDERS RP 57.03, Answers to Motions, provides, "ln no event is a party entitled to more than fourteen (14) days to answer a motion or to file a motion for additional time to IDAHO POWER COMPANY'S MOTION REGARDING RESPONSE TO MOTIONS/JOINDERS.2 answer. The Commission may act upon a motion under Rule 256." However, RP 256.04, Support or Opposition to Prehearing Motion, states: When a prehearing motion has been filed, all parties seeking similar substantive or procedural relief must join in the motion or file their own motion within seven (7) days after receiving the original motion. The party answering to or responding to the motion(s) will have fourteen (14) days from the time of filing of the last motion or joinder pursuant to the requirements of the previous sentence in which to respond, except as provided in Rule 256.02 and 256.03 of this rule. III. REQUESTED RELIEF Here, the initial Motion to Dismiss was filed on January 31, 2014, and several Motions/Joinders were filed on February 7, 2014. ldaho Power intends to file one Answer to all Motions/Joinders filed in this matter, and pursuant RP 256.04 believes its Answerto be due on February 21,2014, fourteen (14) days afterthe filing of the last Motion/Joinder. However, because RP 57 states that a party may not have more than fourteen (14) days to answer a motion, and pursuant to RP 256, ldaho Powe/s Answer would be filed fourteen (14) days after the last Motion/Joinder, but twenty-one (21) days after filing of the initial Motion to Dismiss, ldaho Power requests in the altemative that the Commission grant ldaho Power additional time with which to answer the initial Motion to February 21,2014. DATED at Boise, ldaho, this 14th of February 2014. Attomey for ldaho Power Company IDAHO POWER COMPANY'S MOTION REGARDING RESPONSE TO MOTIONS/JOINDERS - 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 14th day of February 20141 served a true and correct copy of IDAHO POWER COMPANY'S MOTION REGARDING RESPONSE TO MOTIONS/JOINDERS upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Kristine A. Sasser Deputy Attomey General ldaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, ldaho 83720-0074 ldaho Winds LLG Dean J. Miller McDEVITT & MILLER LLP 420 West Bannock Street (83702) P.O. Box 2564-83701 Boise, ldaho 83701 Rick Koebbe, President Idaho Winds LLC 5420 West Wicher Road Glenns Ferry, ldaho 83623 Snake River Alliance Ken Miller, Clean Energy Program Director Snake River Alliance P.O. Box 1731 Boise, ldaho 83701 Gold Springs Windfarm, LLC; Desert Meadow Windfarm, LLC; Hammett Hill Windfarm, LLC; Mainline Windfarm, LLG; Ryegrass Windfarm, LLC; and Two Ponds Windfarm, LLC Peter J. Richardson RICHARDSON ADAMS, PLLC 515 North 27th Street Boise, ldaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX Email kris.sasser@puc.idaho.qov Hand Delivered U.S. Mail Overnight Mail FAX Emai! ioe@mcdevitt-miller. com Hand Delivered U.S. Mail Overnight Mail FAXX Email rk@powenruorks.com _Hand Delivered U.S. Mail Overnight Mail FAX Email kmiller@snakeriveralliance.orq Hand Delivered U.S. Mail Overnight Mail FAXX Email peter@richardsonadams.com IDAHO POWER COMPANY'S MOTION REGARDING RESPONSE TO MOTIONS/JOINDERS - 4 Benjamin G. Huang, Manager c/o Mountain Air Projects 6000 North FoxtailWay Glenns Ferry, ldaho 83623 Cassia Wind Farm LLG; Hot Springs Windfarm, LLC; Bennett Creek Windfarm, LLC; Cassia Gulch Wind Park LLC; Tuana Springs Energy, LLC; and High Mesa Energy, LLG Gregory M. Adams RICHARDSON ADAMS, PLLC 515 North 27th Street Boise, ldaho 83702 PaulAckerman Assistant General Counsel Exelon Business Services Corporation 100 Constellation Way Baltimore, Maryland 21202 American Wind Energy Association and Renewable Northwest Project Teresa A. Hill K&L GATES, LLP One S.W. Columbia Street, Suite 1900 Portland, Oregon 97258 Dina M. Dubson Renewable Northwest Project 421 SW 6h Avenue, Suite 1125 Portland, Oregon 97204 Idaho Wind Partners I, LLC; Meadow Creek Project Company, LLC; and Rockland Wind Farm, LLG Deborah E. Nelson Preston N. Carter GIVENS PURSLEY LLP 601 West Bannock Street (83702) P.O. Box 2720 Boise, ldaho 83701 -2720 Hand Delivered U.S. Mail Overnight Mail FAXX Email bh uano@terna-enerqv. com Hand Delivered U.S. Mail Overnight Mail FAX Email qreg@richardsonadams.com Hand DeliveredX U.S. Mail _Overnight Mail FAX Email Hand Delivered U.S. Mai! Overnight Mail FAXX Email teresa.hill@klqates.com Hand Delivered U.S. Mail Overnight Mail FAXX Email dina@rnp.orq Hand Delivered U.S. Mail Overnight Mail FAXX Emai! den@qivenspursley.com p resto nca rte r@q ive ns p u rsl ev. co m IDAHO POWER COMPANY'S MOTION REGARDING RESPONSE TO MOTIONS/JOINDERS -