20141203Motion to Extend Deadline.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
TELEPHONE: [phone]
E-MAIL: [e-mail]
BAR NO. 66I8
STREET MAILING ADDRESS:
472 WEST WASHINGTON STREET
BOISE, IDAHO 83702.5983
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF FIVE
ENERGY SALES AGREEMENTS FOR THE
SALE AND PURCHASE OF ELECTRIC
ENERGY.
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?01rrDEt -3 PH h:58
) CASE NOS. rPC-E-14-32
) rPC-E-14-33
) rPC-E-14-34
) rPC-E-14-35
) rPC-E-14-36
)) coMMrssroN STAFF MoTroN
) TO EXTEND DEADLINE FOR
) FILING COMMENTS
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
On October 17, 2014, Idaho Power Company filed five Applications with the
Commission each requesting acceptance or rejection of a 2}-year Energy Sales Agreement
(Agreement) with Idaho Power - Murphy Flat Power, IPC-E-14-32; Simco Solar, IPC-E-14-33;
American Falls Solar, IPC-E-14-34; American Falls Solar II, IPC-E-I4-35; and Orchard Ranch
Solar. IPC-E-14-36. On November 6, 2014, the Commission issued Notices of Application and
Notices of Modified Procedure setting a comment deadline for each Project of December 5,
2014. Reply comments were to be filed no later than December 12,2014.
The proposed Agreements have rates calculated based on the incremental cost IRP
Methodology. The issuance of Final Orders (33179,33180) in two similarly situated cases
caused Idaho Power to file Initial Comments on November 20,2014, that modified the pricing
used in the original Applications and Agreements (Replacement Appendices). On December 3,
COMMISSION STAFF MOTION
TO EXTEND DEADLINE FOR COMMENTS
2014, each Project filed Initial Comments that accepted and consented to the use of the
Replacement Appendices provided by Idaho Power in the Company's Initial Comments.
Application of the IRP Methodology involves complicated and detailed calculations
based on different inputs for each Project. Review of the variables and verification of the inputs
used is an arduous task. Staffs review of the inputs and variables used for each Project has
triggered additional questions and the need for additional review. Today, December 3,2014,
Staff filed an additional production request. We have requested that Idaho Power respond no
later than Tuesday, December 9,2014.
In order to provide Staff enough time to receive and adequately review the production
responses, we request an extension for filing comments. Pursuant to Rule of Procedure 256.03,
Staff has provided actual notice by telephone of this motion to counsel for all parties. IDAPA
31.01.01 .256.03. We, therefore, propose the following modifications:
Comments due
Reply comments due
Staff respectfully requests that the
modified schedule.
COMMISSION STAFF MOTION
TO EXTEND DEADLTNE FOR COMMENTS
Friday, December 12, 2014
Friday, December 19, 2014
Commission issue an Order approving the
Respectfully submitted this 344 day of December 2014.
Deputy Attorney General
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF DECEMBER 2014,
SERVED THE FOREGOING COMMISSION STAFF MOTION TO EXTEND
DEADLINE FOR COMMENTS, IN CASE NO. IPC-E-14-34, BY MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN E. WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
P.O. BOX 70
BOISE, TD 83707
E-MAIL: [e-mail]
dockets@idahopower. com
AMERICAN FALLS SOLAR LLC
C/O ARTHUR SNELL
I79 LINCOLN ST STE 5OO
BOSTON MA 02111
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1OI5 W HAYS ST
BOISE TD 83702
E-MAIL: [e-mail]
RANDY C. ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
SARAH LOVELL DIR
COMMERCIAL ASSET MGMNT
12OO FOLSON ST STE IOO
SAN FRANCISCO CA 94103
E-MAIL: slovell@fi stwind.com
SECRETARY
CERTIFICATE OF SERVICE