20070223Application.pdf

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February 23, 2007
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Ms. Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ill 83720-0074
Re:
201 South Main, Suite 2300
Salt lake City, Utah 84111
Motion For Extension of Time to File 2006 Integrated Resource Plan
PAC-07-
Dear Ms. Jewell:
Rocky Mountain Power, a division ofPacifiCorp ("RMP" or the "Company ), hereby submits for
filing an original and seven copies of its Motion for Extension of Time to File 2006 Integrated Resource
Plan.
Service of pleadings, exhibits, orders and other documents relating to this proceeding should be served on
the following:
Dean Brockbank
Senior Counsel
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Dean.B rockbank~Pac ifi Corp. com
Brian Dickman
Manager, Idaho Regulatory Affairs
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT 84111
Brian.Dickman~Paci fi Corp .com
In addition, it is respectfully requested that all formal correspondence and Staff requests regarding this
material be addressed to:
By E-mail (preferred):datareq uest~pac ificorp. com
By Fax:[phone]
By Regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
Sincerely,
~I
Jeffrey K. Larsen
Vice President, Regulation
Enclosure
Dean Brockbank
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
FAX: [phone]
Dean.Brockbank~Pacifi Corp. com
Attorney for Rocky Mountain Power
IN THE MATTER OF THE FILING OF
ROCKY MOUNTAIN POWER OF ITS 2006 )
ELECTRIC INTEGRATED RESOURCEPLAN
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. P AC-0 3
MOTION FOR EXTENSION OF
TIME TO FILE 2006 INTEGRATED
RESOURCE PLAN
COMES NOW Rocky Mountain Power, a division ofPacifiCorp ("RMP" or the
Company ), and hereby moves the Idaho Public Utilities Commission ("IPUC" or the
Commission ) for an order authorizing an extension oftime for filing its 2006 Integrated
Resource Plan ("IRP"). This Motion is based on the following:
Pursuant to Commission Order No. 22299 issued in Case No. U-1500-165 , RMP
biennially files its IRP. That filing requirement was reaffirmed in Order No. 27835 issued in
Case No. UPL-98-4 when the Commission directed the Company to file an IRP in December
2000 and every two years thereafter. As initially communicated to the Commission in a letter
dated January 16 2007, the Company s ability to complete and file its 2006 IRP has been
impacted by various issues as described below, and RMP respectfully requests the Commission
authorize the Company to file its 2006 IRP on or before May 30, 2007.
MOTION OF ROCKY MOUNTAIN POWER
II.
Rocky Mountain Power was recently created when PacifiCorp was acquired by
MidAmerican Energy Holdings Company ("MEHC"), approved by the Commission on March
2006 in Order No. 29998. The Company continues the process of integration into the MEHC
group, and the 2006 IRP will be the first filed under MEHC ownership. The Company only just
finished its first long-range planning cycle under MEHC, the results of which were presented to
the Commission on January 10 2007. PacifiCorp intends to incorporate the outcome ofthat
planning process into its IRP in order to produce a viable plan that the Company can be judged
against in the future. Due to similar timing anticipated in future business planning cycles under
MEHC, PacifiCorp respectfully requests that the Commission authorize the Company to file
future IRPs by the last business day of March on a biennial basis beginning in 2009.
II1.
The Company is currently in the process of drafting a 2012 Request for Proposal ("RFP"
to procure additional long-term resources. While Utah and Oregon require approval of the draft
RFP, neither state has yet approved it. In fact, Oregon has rejected the current draft while Utah
continues its approval process. The Company has received divergent feedback during the
process in the respective jurisdictions and feels it necessary to incorporate insights gained from
the respective approval processes into its 2006 IRP. Additional time is required to allow the
public process to continue its course and reflect the most current conditions in the IRP filing.
IV.
Service of pleadings, exhibits, orders and other documents relating to this proceeding
should be served on the following:
MOTION OF ROCKY MOUNTAIN POWER
Dean Brockbank
Senior Counsel
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Dean.Brockbank~Pacifi Corp. com
Brian Dickman
Manager, Idaho Regulatory Affairs
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT 84111
Brian. Di ckman~P acifi Corp. com
In addition, it is respectfully requested that all formal correspondence and Staff requests
regarding this material be addressed to:
By E-mail (preferred):datareQ ue st~pac ifi corp. com
By Fax:[phone]
By regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
WHEREFORE, PacifiCorp respectfully requests the Commission authorize the Company
to file its 2006 IRP on or before May 30, 2007, and then file every two years thereafter by the
last business day of March.
Respectfully submitted this 23rd day of February 2007.
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/\.
Dean Brockbank
Attorney for PacifiCorp
MOTION OF ROCKY MOUNTAIN POWER