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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