20141106Reply Comments.pdf

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An IDACORP Companv
November 6,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-24
lmplementation of Tariff Schedule 73 - ldaho Power Company's Reply
Comments
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and seven (7)
copies of ldaho Power Company's Reply Comments.
yours,
DONOVAN E. WALKER
Lead Gounsel
DEW:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
122'l West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@idahopower. com
Aftorney for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL AND IMPLEMENTATION OF
SCHEDULE 73, COGENERATION AND
SMALL POWER PRODUCTION.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. !PC-E-14-24
IDAHO POWER COMPANY'S
REPLY COMMENTS
ldaho Power Company ("ldaho Powe/'), in response to the Comments filed by
the ldaho Public Utilities Commission ("Commission") Staff and the Comments filed by
J. R. Simplot Company, hereby respectfully submits the following Reply Comments.
I. STAFF'S COMMENTS
1. ldaho Power appreciates Staffs careful review and recommendation for
approval of ldaho Powe/s proposed Schedule 73. ldaho Power notes Staff confirmed
that ldaho Powe/s proposed Schedule 73 was developed to closely match Avista's
approved Schedule 62. Staffs ultimate re@mmendation is "that the minor differences
between Avista's approved Schedule 62 and Idaho Powe/s proposed Schedule 73 are
either not material or alternatively, appropriate to tailor the content to ldaho Power.
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
Staff recommends approval of ldaho Power's Schedule 73 as proposed." Staff
Comments, p. 5.
II. J. R. SIMPLOT COMPANY'S COMMENTS
2. J. R. Simplot Company ("Simplot") filed Comments stating that it has no
objection to the overall structure of ldaho Powe/s proposed Schedule 73, but objecting
to (or recommending changes to) two items from ldaho Powe/s proposed Schedule 73:
(1) the legally enforceable obligation Ianguage regarding the qualifying facility's ability to
deliver electrical output within 365 days of a legally enforceable obligation determination
and (2) language regarding the completion of interconnection studies.
3. Simplot's objections are without merit. These objections are literally the
exact same objections-with the exact same wording-as those that were raised by
Sagebrush Energy, LLC, with regard to the same provisions in Avista's Schedule 62.
As such, these objections were all ready considered, and rejected, by the Commission
in its consideration and approval of Avista's Schedule 62. The provisions objected to
from ldaho Powe/s proposed Schedule 73 match exactly the corresponding provisions
from Avista's approved Schedule 62, which were approved by the Commission after its
consideration of these exact same arguments now submitted by Simplot.
Consequently, these objections have all ready been appropriately addressed and
resolved by the Commission.
ilt. coNcLustoN
ldaho Power respectfully requests that the Commission issue an order
authorizing the implementation of the proposed tariff Schedule 73, including the
Application form.
IDAHO POWER COMPANY'S REPLY COMMENTS.2
Respectfully submitted this 6h day of November 2014.
DONOVAN E. WALKER
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6h day of November 20141 served a true and
conect copy of IDAHO POWER COMPANY'S REPLY COMMENTS 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 83720-007 4
X Hand Delivered
_U.S. Mai!
Overnight Mail
FAXX Email [e-mail]
Christa Bearry, Legal Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 4