HomeMy WebLinkAbout20260326Comments.pdf 7N AHO R®
RECEIVED
M
DONOVAN WALKER arch 26, 2026
Lead Counsel IDAHO PUBLIC
dwalker(cDidahopower.com UTILITIES COMMISSION
March 26, 2026
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-26-03
Idaho Power Company's Application for Approval of the 2032 All-Source
Request for Proposals to Meet Capacity Resource Needs in as Early as 2031
Dear Commission Secretary:
Idaho Power Company ("Idaho Power" or "Company") hereby provides notice to
the parties of this case of a proposed revision to the draft 2032 Request for Proposals
("RFP") filed as part of the Company's request in this case.
As described in Idaho Power's Application, coincident to filing the request in this
proceeding, the Company posted the draft 2032 RFP on Idaho Power's Request for New
Resources webpage, providing notice to the public of the upcoming solicitation. In
addition, Idaho Power notified all registered users through the Zycus sourcing platform,
identifying the due date for proposals. The intent on providing interested bidders the draft
2032 RFP in advance of the formal solicitation is to ensure bidders have the opportunity
to submit potential projects into the annual Generator Interconnection Cluster Request
Window study, which runs from March 1, 2026, through April 15, 2026.
Within the Zycus sourcing platform, interested bidders can submit a Request for
Information to the Company. This process allows potential bidders to ask administrative
or clarifying questions of Idaho Power as it pertains to the requirements of the RFP.
Through this process, a bidder requested clarification pertaining to the following proposed
requirement outlined in the Network Upgrades section of page 15 of the draft 2032 RFP:
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707
Commission Secretary
Idaho Public Utilities Commission
March 26, 2026
Page 2
"With respect to transmission service, for resources that will be owned in
full or in part by IPC or for which IPC will have an executed contract for the
purchase of the generation, IPC anticipates it will designate the resource or
executed contract as Network Resources of IPC under the OATT upon
commercial operation of the resource or first delivery date under the
contract. Projects that are seeking to interconnect to IPC's system must
request Network Resource Interconnection Service (NRIS)."
While researching the bidder request, Idaho Power determined the requirement
was inadvertently overly prescriptive and therefore the Company proposes the following
change to the draft 2032 RFP language (revisions are made in redline):
"With respect to transmission service, for resources that will be owned in
full or in part by IPC or for which IPC will have an executed contract for the
purchase of the generation, IPC anticipates it will designate the resource or
executed contract as Network Resources of IPC under the OATT upon
commercial operation of the resource or first delivery date under the
contract. Projects that are seeking to interconnect to IPC's system must
have submitted a GI request network ReseuFGe InteMonneGtinn Sewn o
The update would also need to be reflected in the Bid Eligibility Factor section of Exhibit
B — Bid Entry Form and therefore Idaho Power proposes the additional change to the
draft 2032 RFP Exhibit B:
Resource Based Proposal -The Bidder has made appliGation for NetworL
Integration rterGORnec irrOR Service (nIRIS) for the FaGility and is in the IPC
Generator Interconnection Queue and will be delivered to a Point of Delivery
on IPC's transmission system OR if the Facility will be interconnected to a
third-party transmission system, Bidder has provided documentation that
demonstrates it has submitted applicable transmission service requests to
the relevant Transmission Provider to establish transmission rights to
deliver to IPC point of delivery.
The update would also need to be reflected in Exhibit FA — Draft Form Agreements for
Resource Based Bids and therefore Idaho Power proposes the additional change to the
draft 2032 RFP Exhibit FA:
Commission Secretary
Idaho Public Utilities Commission
March 26, 2026
Page 3
The Buyer will be required to pursue and procure network ros^FGe
interconnection service ``"'that equals or exceeds the Guaranteed
Capacity, and full deliverability of at least the Guaranteed Capacity from the
Facility to Buyer's load on a firm network resource basis for the life of the
Facility, (collectively, "Full Deliverability"), where applicable.
The Company is providing this notice to parties of the proposed changes to the
draft 2032 RFP to allow time for parties' review and/or comment. If you have any
questions about any of the aforementioned information, please do not hesitate to contact
me.
Very truly yours,
Donovan E. Walker
DEW:sg
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26th day of March 2026, 1 served a true and
correct copy of Idaho Power Company's Comments upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Jeffrey Loll U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8 FTP Site
Suite 201-A (83714) X Email
PO Box 83720 Jeff.loll puc.idaho.gov
Boise, ID 83720-0074
Idaho Irrigation Pumpers Association, Hand Delivered
Inc. U.S. Mail
Eric L. Olsen Overnight Mail
Echo Hawk & Olsen, PLLC FAX
505 Pershing Ave., Ste. 100 FTP Site
Pocatello, Idaho 83205 X Email
elo echohawk.com
taysha _echohawk.com
Lance Kaufman, Ph.D. Hand Delivered
Deborah Glosser, Ph.D. U.S. Mail
2623 NW Bluebell Place Overnight Mail
Corvallis, OR 97330 FAX
FTP Site
X Email
lance aegisinsight.com
Deborah.glosser(cD_g mail.com
Northwest Intermountain Power Hand Delivered
Producers Coalition U.S. Mail
Gregory M. Adams Overnight Mail
Richardson Adams, PLLC FAX
515 N. 27t" Street FTP Site
Boise, Idaho 83702 X Email
greg(o)_richardsonadams.com
CERTIFICATE OF SERVICE- 1
Irion Sanger Hand Delivered
Sanger Greene, PC U.S. Mail
4031 SE Hawthorne Blvd. Overnight Mail
Portland, OR 97214 FAX
FTP Site
X Email
irion sanger-law.com
Spencer Gray Hand Delivered
Executive Director U.S. Mail
P.O. Box 504 Overnight Mail
Mercer Island, WA 98040 FAX
FTP Site
X Email
sgray(@-nippc.orq
CITY OF BOISE CITY Hand Delivered
Ed Jewell U.S. Mail
Boise City Attorney's Office Overnight Mail
150 N. Capitol Blvd. FAX
Boise, ID 83701 FTP Site
X Email
eiewell(o)-cityofboise.org
boisecityattorney(a)-cityofboise.org
Katie O'Neil Hand Delivered
Energy Program Manager U.S. Mail
Boise City Department of Public Works Overnight Mail
150 N. Capitol Blvd. FAX
Boise, Idaho 83701 FTP Site
X Email
koneil(a)cityofboise.org
MICRON TECHNOLOGY, INC. Hand Delivered
Austin Rueschhoff U.S. Mail
Thorvald A. Nelson Overnight Mail
Richard A. Arnett FAX
Holland & Hart LLP FTP Site
555 17th Street, Suite 3200 X Email
Denver, CO 80202 darueschhoff(a)_hol land hart.com
tnelson(a-hollandhart.com
raarnett(a-hollandhart.com
aclee(q)_hol land hart.com
tlfriel(a)_hol land hart.com
CERTIFICATE OF SERVICE-2
Stacy Gust
Regulatory Administrative Assistant
CERTIFICATE OF SERVICE-3