20141224Motion to Sur-Reply.pdf

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McDevitt & Miller LLP
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420 West Bannock Stteet
P.O. Box 2564-83701
Boise,Idaho 83702
Decembet 24,201,4
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DeanJ. (oe) Millet
Celeste IL Miller
Yia llaad Delivety
JeanJewell, Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise,Idaho 83720
Re: IPC-E-14-26 Mountain Home Solat, LLC
IPC-E,-14-27 Pocatello Solat 1, r-r 6
IPC-E-14-28 Cla* Solat 1, LLC
IPC-E-14-29 Clark Solar 2, r'r Q
IPC-E'14-30 Clatk Solar3, I.r'g
IPC-E-14-31 Clatk Solar 4, LLC
Deat Ms. Jewell:
Enclosed for filing, please find an odginal and seveo (f copies of a Motion To Petmit Fili"g of Sur-
Reply Comments for each of the cases listed above.
An additional copy of these documents and letter are included fot return to me with your file stamp
thereon.
DJM/hh
Enclosures
Very Truly Yours,
Dean J. Miller (ISB No. 1968)
McDEVITT & MILLER LLP
420 West Bannock Steet
P.O. Box 2564-83701
Boise, D 83702
Tel:[phone]
Fax: [phone]
i oe@mcdevitt-miller. com
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Attorneyfor Mountain Home Solar, LLC, Pocatello Solar l, LLC, Clark Solar l, LLC, Clark
Solar 2, LLC, Clark Solar 3, LLC, and Clark Solar 4, LLC
BEFORE TIIE IDAIIO PT]BLIC UTILITIES COMMISSION
IN TIIE MATTER OF THE APPLICATION
OF IDAHO POWER COMPAI\rY FOR
APPROVAL OR REJECTION OF A}[
ENERGY SALES AGREEMENT WITH
MOUNTATN rrOME SOLA& LLC, FOR
THE SALE AIID PURCHASE OF
ELECTRIC ENERGY.
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPAIYY FOR
APPROVAL OR REJECTION OF AI\
ENERGY SALES AGREEMENT WITII
POCATELLO SOLAR I,LLC, FOR THE
SALE AI\D PURCHASE OF ELECTRIC
ENERGY.
IN TIIE MATTER OF THE APPLICATION
OF IDAHO POWER COMPAIIY FOR
APPROVAL OR REJECTION OF AI\
ENERGY SALES AGREEMENT WITH
CLARI( SOLAR I,LLC, FOR THE SALE
AND PURCHASE OF ELECTRIC
ENERGY.
) CASE NO. rPC-E-r4-26
)) MOTTON TO PERMTT FTLTNG OF
) SUR-REPLY COMMENTS
)
)
)
) CASE NO. rPC-E-14-27
)
)
)
)
)
)
) CASE NO. rPC-E-r4-28
)
)
)
)
)
)
MOTION TO PERMIT TILING OF SUR-REPLY COMMENTS.I
IN THE MATTER OF TIIE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
CLARK SOLAR 2,LLC, FOR THE SALE
AND PURCHASE OF ELECTRIC
ENERGY.
) cAsE NO. rPC-E-14-29
)
)
)
)
)
)
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITII
CLARI( SOLAR 3,LLC, FOR THE SALE
AND PURCHASE OF ELECTRIC
ENERGY.
CASE NO.IPC.E.14.3O
IN THE MATTER OF TIIE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AI\
ENERGY SALES AGREEMENT WITH
CLARI( SOLAR 4,LLC, FOR THE SALE
AND PURCIIASE OF ELECTRIC
ENERGY.
CASE NO. IPC.E.I4.3I
COMES NOW Intermountain Energy Partners (IEP), on behalf of the above captioned
projects, and moves the Commission, pursuant to RP. 56 and 256, for an order permitting filing
of Sur-Reply Comments, to be filed no later than January 5,2075, and in support thereof
respectfully shows as follows, to wit:
1. Commission Orders and Notices issued in these matters established a Comment
deadline of December 19,2014 and a Reply deadline of December 26,2014.
2. Previously, on November 20,2014,Idaho Power Company (Idaho Power) filed
Initial Comments updating pricing schedules in the Energy Sales Agreements (ESAs) taking into
account adjustments approved by the Commissionin Boise City Solar.
MOTION TO PERMIT FILING OF SUR-REPLY COMMENTS-2
3. The remaining major issue (putting aside whether to approve minor pricing
adjustments recommended by Commission Staff) is whether the Commission should approve
ESAs containing prices set forth in Exhibit E or Exhibit F (as adjusted) of the ESAs. (The "Ex E
or Ex. F Issue").
4. On December 19,2014,IEP filed Initial Comments addressing the Ex. E or Ex. F
Issue. Commission Staff filed Comments on the same date and touched on the Ex. E or Ex. F
Issue.
5. Idaho Power did not file Comments on December 19,2014.
6. Instead, Idaho Power filed Reply Comments on December 23,2014 nwhich
Idaho Power set forth its views on the Ex. E or Ex F issue.
7. IEP desires, and should be permiued, to respond to Idaho Power's Reply
Comments.
8. Taking into account holiday schedules and the time required to prepare a
thoughtful response on the Ex. E or Ex. F issue, IEP requests the Commission to set January 5,
2015 as the date for filing Sur-Reply Comments.
9. The undersigned has spoken to counsel for Commission Staff, and is informed
Staffdoes not object. The undersigned has spoken to counsel for Idaho Power, and is informed
Idaho Power will not file a iormal objection.
Dated ttris Lq\ day of December, 2014.
By:
Attorneyfor Mountain Home Solar, LLC, Pocatello
Solar 1, LLC, Clark Solar l, LLC, Clark Solar 2,
LLC, Clark Solar 3, LLC, and Clark Solar 4, LLC
MOTION TO PERMIT FILINGOF SUR.REPLY COMMENTS-3
CERTIFICATE OF SERVICE
I hereby certiff that on tne$faay of Decernb er,20l4,I caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
P.O. Box 83720
Boise,lD 83720-0074
jj ewell@ouc. state.id.us
Kristine Sasser, Deputy Attomey General
Idaho Public Utilities Commission
472W. Washington St.
Boise,Idaho 83720
kris. [e-mail]. gov
Donovan E. Walker
Randy C. Allphin
Regulatory Dockets
Idatro Power Company
1221 West Idaho Street
P.O. Box 70
Boise, lD 83707
dwalker@i dahopower. com
rallphin@idahopower. com
do ckets@idahopower. com
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MOTION TO PERMIT FILING OF SIJR-REPLY COMMENTS.4