20171114Errata to ICEA Answer.pdf

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An loAcoRP companY
LISA D. NORDSTROM
Lead Counsel
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RECEIVED
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November 14,2017
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
47 2 W est Wash i ngton Street
Boise, Idaho 83702
Re Case No. IPC-E-17-13
New Schedules for Residential and Small General Service Customers with
On-Site Generation - ldaho Power Company's ERRATA to lts Answer to the
ldaho Clean EnergyAssociation's Motion to Dismiss
Dear Ms. Hanian:
Enclosed for filing in the above matter please find an original and seven (7) copies
of ldaho Power Company's ERRATAto ItsAnswerto the ldaho Clean EnergyAssociation's
Motion to Dismiss.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
LDN:kkt
Enclosures
6n"K;k/d'e'+-
LISA D. NORDSTROM (lSB No. 5733)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom @ idahopowel. cem
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORIry TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION
RECEIVED
?0l1lt0Y lb Pl{ h: 28
i r i irir?i,ri-iS#l8t'o*
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-17-13
IDAHO POWER COMPANY'S
ERRATA TO ITS ANSWER TO
THE IDAHO CLEAN ENERGY
ASSOCIATION'S MOTION TO
DISMISS
On November 13, 2017 ,ldaho Power Company filed its Answer to the ldaho Clean
Energy Association's Motion to Dismiss. The two full paragraphs on page 4 in the
Background section currently read:
On October 27, 2017, ICEA filed a Motion to Dismiss
and Memorandum in support thereof, Auric Solar, LLC ("Auric
Solar") filed a Joinder and Memorandum in Support of !CEA's
Motion to Dismiss, and the City of Boise ("Boise City") filed a
Memorandum Joining in Support of and Providing Comments
to ICEA's Motion to Dismiss. Following the October 27
deadline for dispositive motions established in Commission
Order No. 33901, the ldaho Conservation League ("!CL") filed
a Partial Joinder on November 1 , 2017. On November 3,
2017, the ldaho Sierra Club filed its Partial Joinder to ICEA's
IDAHO POWER COMPANY'S ERRATA TO ITS ANSWER TO THE
IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 1
Motion to Dismiss, lntermountain Wind and Solar, LLC filed a
Partial Joinder in Motion to Dismiss and Memorandum in
Support of Motion to Dismiss, and the Snake River Alliance
("SRq'; and NW Energy Coalition jointly filed a Joinder and
Memorandum in Support of !CEA's Motion to Dismiss. ldaho
Power refers herein to these parties collectively as "Movants."
The Movants argue in ICEA's Motion to Dismiss and
their Joinders thereto that the above language in Order No.
32846 bars consideration of the issues presented in the
present docket. ldaho Power strongly disagrees.
This section should read
On October 27,2017, ]CEA filed a Motion to Dismiss
and Memorandum in support thereof, Auric Solar, LLC ("Auric
Solar") filed a Joinder and Memorandum in Support of ICEA's
Motion to Dismiss, and the City of Boise ("Boise City") filed a
Memorandum Joining in Support of and Providing Comments
to ICEA's Motion to Dismiss. Following the October 27
deadline for dispositive motions established in Commission
Order No. 33901, the ldaho Conservation League ("lCL") filed
a Partial Joinder on November 1 , 2017. On November 3,
2017 , the ldaho Sierra Club filed its Partial Joinder to ICEA's
Motion to Dismiss, lntermountain Wind and Solar, LLC filed a
Partial Joinder in Motion to Dismiss and Memorandum in
Support of Motion to Dismiss, and the Snake River Alliance
("SR,q'; and NW Energy Coalition jointly filed a Joinder and
Memorandum in Support of ICEA's Motion to Dismiss. The
Partial Joinders to ICEA's Motion to Dismiss filed bv ICL
and the Sierra Club appear to ioin ICEA's request for
alternative relief but not dismissal of the
case. lntermountain Wind and Solar. LLC's Partial
Joinder in Motion to Dismiss appears tg support
dismiqsal of the case but contemplates a different
formulation of alternative relief. However. to facilitate
the filinq of a comprehensive answer to these six filinqs.
ldaho Power refers herein to these parties collectively as
"Movants."
The Movants argue in ICEA's Motion to Dismiss and
some of their Joinders thereto that the above language in
Order No. 32846 bars consideration of the issues presented
in the present docket. ldaho Power strongly disagrees.
IDAHO POWER COMPANY'S ERRATA TO ITS ANSWER TO THE
IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS .2
DATED at Boise, ldaho, this 14th day of November 2017
p
D
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S ERRATA TO ITS ANSWER TO THE
IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 3
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 14th day of November 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S ERRATA TO ITS ANSWER TO THE
IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Conseryation League
Matthew A. Nykiel
ldaho Conservation Leag ue
102 South Euclid #207
P.O. Box 2308
Sandpoint, ldaho 83864
Benjamin J. Otto
ldaho Conservation League
710 N.6th st.
Boise, ldaho 83702
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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erin. [e-mail]
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IDAHO POWER COMPANY'S ERRATA TO ITS ANSWER TO THE
IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 4
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 W. Bannock Street
Boise, ldaho 83702
Elias Bishop
Auric Solar, LLC
2310 S. 1300 W.
West Valley City, Utah 84119
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 1 1
Briana Kobor
Vote Solar
360 22nd Street, Suite 730
Oakland, California 94612
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701 -0500
ldaho Clean Energy Association
C. Tom Arkoosh
ARKOOSH LAW OFFICES
P.O. Box 2900
Boise, ldaho 83701
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X Email prestoncarter@q ivenspurslev.com
den@g ivenspu rsley.com
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x Email [e-mail]
eri n. ceci l@arkoosh. com
IDAHO POWER COMPANY'S ERRATA TO ITS ANSWER TO THE
IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 5
David H. Arkoosh
Law Office of David Arkoosh
P.O. Box 2900
Boise, ldaho 83701
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
Zack Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River Alliance
NW Energy Goalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capito! Boulevard, Suite 701
Boise, ldaho 83702
lntermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
KIRTON McCONKIE
50 East South Temple, Suite 400
P.O. Box 45120
Salt Lake City, Utah 84111
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wwi lson @snakeriveral I ia nce org
[e-mail]
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[e-mail]
IDAHO POWER COMPANY'S ERRATA TO ITS ANSWER TO THE
IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 6
Doug Shipley
Dale Crawford
!ntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
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rly Towell,Assista
IDAHO POWER COMPANY'S ERRATA TO ITS ANSWER TO THE
IDAHO CLEAN ENERGY ASSOCIATION'S MOTION TO DISMISS - 7